Tax treaties are based on a set of common principles designed to eliminate double taxation that may occur in the case of cross-border trade and investments. The current network of bilateral tax treaties dates back to the 1920s and the first Model Tax Convention developed by the League of Nations. The Organisation for Economic Co-operation … More The Multilateral Instrument and the future of bilateral tax treaties
“As one more Indian fiscal year ended, it was yet again time to think of the various tax and fiscal developments in our country. On the airplane returning from an overseas trip in the first week of the new fiscal year, the familiar and comforting voice of the lady pilot announced the landing in Mumbai.
Unveiling the Budget 2016–17, Mr. Arun Jaitley, the Finance Minister, stated that the Budget proposals were built on the agenda of “Transforming India” with “nine distinct pillars”, including tax reforms, promoting ease of doing business and ensuring fiscal discipline.
In 2015, there were exceptional changes in the global tax landscape — Base Erosion and Profit Shifting (BEPS) discussion drafts turned into final recommendations with many jurisdictions already legislating on a unilateral basis in anticipation of final recommendations. Across the globe, new and sometimes highly novel national legislation was released to address BEPS challenges. The … More Budget 2016 – what does it entail from BEPS perspective
The NDA Government’s second Union Budget is coming at rather interesting crossroads, from the point of view of international taxation. On one hand, there is persistent reinstatement of efforts toward having a non-adversarial tax regime; while on the other, legislative enforcement of the OECD Base Erosion and Profit Shifting (BEPS) recommendations, which have changed the … More Union Budget 2016-17: decoding the Government’s stand on cross-border taxes
Different countries may have different ways in which they choose to set the jurisdiction for tax under the residence principle. However, there is a degree of consensus on the basic principle that there should be a fairly strong economic nexus with that country. Two basic approaches are used in establishing a personal jurisdictional connection for … More Place of Effective Management (POEM): striking the right balance
Over several decades and in step with the globalization of the economy, world-wide intra-group trade has grown exponentially. Transfer pricing rules, which are used for tax purposes, are concerned with determining the conditions, including the price, for transactions within a multi-national enterprise (MNE) group resulting in the allocation of profits to group companies in different … More BEPS, value creation and transparency