Place of Effective Management – Decoding UK’s Development Securities decision in the Indian context

Determination of tax residence based on the Place of Effective Management (PoEM) has been in force in India since April 2016, with guidance and clarification from tax authorities issued in January 2017. The guidance[1] has shed more light on cases that the Government intends to cover within the ambit of the PoEM regulations. However, as … More Place of Effective Management – Decoding UK’s Development Securities decision in the Indian context

India’s position on the “2017 OECD update”: Deviating from an international consensus?

Recently, OECD released an update to the OECD model convention and commentary (“2017 update”). The 2017 update largely consists of amendments agreed upon as part of the BEPS project and follow up work thereon. In addition, it incorporates certain other changes that were released for public comments previously and finalized now. It also contains the … More India’s position on the “2017 OECD update”: Deviating from an international consensus?

Relaxation from application of indirect transfer provisions to alternative investment funds

The transfer of share or interest in a foreign company or entity deriving substantial value from assets located in India is taxable in India. However, where such transfer outside India is a consequence of a direct redemption or sale of an investment in India which is chargeable to tax in India, application of indirect transfer … More Relaxation from application of indirect transfer provisions to alternative investment funds

Blockchain technology: Possible future of digital transfer pricing

Change is certain, and the digital world is changing exponentially. It started with smartphones, which impacted the masses and led to the emergence of smart lives. As digitization and automation continue, it is now the time for smart businesses. Among many fast-emerging disruptive technologies, blockchain technology seems to have the potential to revolutionize businesses and … More Blockchain technology: Possible future of digital transfer pricing

Taxation in digital economy, making way legally

Digitalization of the global economy has happened at a tremendous pace and a large scale, permeating almost all areas of society. However, emergence of new business models have made it harder to tax businesses possessing a digitalized value chain. Conventional source allocation rules related to brick and mortar structures are not apt for the digital … More Taxation in digital economy, making way legally

Master file notification: Expectations, impact and risk areas for MNCs

The Organisation for Economic Co-operation and Development (OECD) commenced work on the Base Erosion and Profit Shifting (BEPS) project to address concerns that existing principles of domestic and international taxation were failing to keep pace with the global nature of modern business models. As a member of the G20 and an active participant in the … More Master file notification: Expectations, impact and risk areas for MNCs