OECD

Much changed in the world of taxation the last couple of years. The OECD started and finished the BEPS (Base Erosion and Profit shifting) project. The objective of BEPS was to develop rules that…

A recent ruling in GE Money Financial Services Pvt. Ltd. v. DCIT, the Income Tax Appellate Tribunal (ITAT) has further contributed to the uncertainties in Transfer Pricing in India. The ruling is a…

Italy has embarked upon the challenging task of redesigning its tax system.  The Act[1] of late November 2016 (hereinafter, “Act”) constitutes a best-practices example, or at least for our Country…

India has entered into more than 100 double tax avoidance agreements with foreign nations. Almost all these tax treaties contain an article on Mutual Agreement Procedure (MAP) setting out how India…

In the EU Commission’s view a tax ruling (hereinafter “APA”) confers on the beneficiary a selective advantage under Art. 107(1) of the Treaty on the Functioning of the European Union (hereinafter …

On 24 November 2016, the OECD released the Multilateral Convention designed for the implementation of tax treaty measures related to the Base Erosion and Profit Shifting (“BEPS”) Project. The…

“A camel is an animal designed by a committee” – Anonymous In launching the BEPS programme in 2013, the OECD warned that replacement of the current consensus-based framework by unilateral measures,…

The recent appearance of the Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or the Convention)[1] rounded up the implementation of…

Publication of text of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) by the OECD on 24 November 2016 is one of the…