BEPS

Taxation of the digital economy has become a war in the post-BEPS world. As with any war, there are more or less clear rivals and there will be of course winners and losers. It goes without saying…

BEPS Action Plan 6 observes that corporations are misusing Double Taxation Avoidance Agreement (DTAA) provisions by indulging in treaty shopping. A typical example of treaty abuse that BEPS Action…

I wrote in my last blog that despite its impact, corporate tax avoidance is one of the lesser debated issues in India. This is what I wrote: “Multinational tax avoidance has almost never made it to…

In 1789, Benjamin Franklin wrote in a letter to French scientist Jean-Baptiste Leroy: “Our new Constitution is now established, and has an appearance that promises permanency; but in this world…

The financial crisis of 2008 and the Great Recession that followed led to millions losing their jobs and their homes. In Europe, the governments reacted to the pressure on the Eurozone by imposing…

The proposal for upholding a minimum effective tax rate on corporate profits, on which the OECD Inclusive Framework recently invited comments, has received a lot of criticism. A minimum tax would…

Transfer pricing cases in India are estimated to account for more than half of the world’s transfer pricing disputes. Prolonged transfer pricing litigation due to overburdened courts and tribunals is…

On 30 August 2018 the OECD released the fourth round of BEPS Action 14 peer review reports on improving tax dispute resolution mechanisms. Included in this round was a report on Australia. The report…

If the BEPS Project is considered formally concluded with the signature of the Multilateral Instrument, the war against base erosion and aggressive tax planning is still ongoing, with many battles…