India

While earthlings are grappling with taxation in a digitalised world, a new and important frontier has been opening up somewhat less observed. Commercial exploitation of space has become commonplace…

Globally, countries are making a concerted effort to rein in the direct tax challenges posed by the digital economy. Some of this work is directly inspired by the recommendations set out by the OECD…

In this blog, I shall examine the policy and characteristics underlying the split-rate system of taxing corporate profits/income. I shall also discuss the issue whether the Indian Dividend…

Earlier this month, the author of this blog was at the IFA UK branch meeting where experts assembled to discuss certain interpretational aspects concerning the BEPS Multilateral Instrument (BEPS MLI)…

The Income Tax Appellate Tribunal (hereinafter referred to as the “Tribunal”), Mumbai delivered a landmark judgment in the case involving two parties namely, Elsevier Information Systems Gmbh and Dy…

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…

There has been much brouhaha about equalization levies in the context of the digital economy. One of the hotly debated issues is whether such levies are covered by tax treaties at all. In this post,…

Taxation of the digital economy is one of the more difficult and contentious issues in international taxation. There are several strands to this complexity. One strand is profit attribution for…