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
Formulating anti-BEPS (Base Erosion and Profit Shifting) measures for cases where companies were deemed to not have a Permanent Establishment (PE) despite substantial business activity, was a key priority for the Organisation for Economic Cooperation and Development (OECD) in its BEPS project. Recommendations and outcomes from the OECD Action Plan 7 of the BEPS project, … More The evolution and rethink of the Permanent Establishment concept as a consequence of BEPS
Gaurav Karnik, Tax Partner and Leader – Real Estate practice, EY India It is that time of the year when the entire industry looks forward to the Finance Minister Arun Jaitely’s speech on Budget Day to provide much needed relief and growth impetus in various sectors. The real estate sector is no different, given the … More What Budget 2017 may look like for the real estate sector
The year 2016 witnessed a rapid movement of the OECD-G20 BEPS project to the implementation phase, leaving a fundamentally changed landscape in its wake. Now that all the key instruments for BEPS implementation have been released by the OECD, countries are legislating and/or providing more clarity on how they will implement BEPS measures so that … More Budget 2017: what international tax may have in store for you!
With an ever-evolving global taxation landscape, it has become essential to be in sync with the changing rules and regulations. The OECD BEPS global tax agenda has led to various countries proposing/implementing changes in their local laws to align with the themes laid out in the BEPS Action Plans. Recently the OECD released the text … More The road to counter BEPS
Globalization has brought about a boom in the movement of employees to different countries to acquire specialized technical skill and expertise. Over the years, we have seen organizations coming out with various assignment models to send their employees abroad. This trend offers many benefits to employees apart from bolstering their career and creating an international … More Global mobility and evolving changes
Buyback tax (BBT) provisions were introduced in the Income Tax Laws (ITL) in 2013 to check tax avoidance by unlisted companies, which resorted to buyback of shares instead of dividend distribution, particularly where the buyback distribution proceeds were tax-exempt for overseas shareholders under the treaty network. BBT is payable by domestic unlisted companies in the … More Taxation of buybacks by unlisted companies: a step toward greater clarity?