On February 1, 2017, India’s Finance Minister, Arun Jaitley, presented the country’s 2017-18 Budget, which contains several tax proposals in the area of international tax law, including the…
There are several misconceptions in international taxation, some of them more pervasive than others. Many are often repeated by speakers at tax conferences without being contradicted.
The first is…
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 “…
The European Union’s Court of Justice finally rendered its judgement in the famous Banco Santander and Autogrill cases on 21 December 2016. For state aid specialists and tax lawyers this decision was…
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,…
