Recommendations of OECD: Reworking Exceptions to PE Definition: To define PE all activities carried on by enterprises along with activity by closely related shall be examined. Analyzing Arrangements Entered Through Contractual Agreements: Business…
Category: Base Erosion and Profit Shifting (BEPS)
Action Plan 12-Disclosure Of Aggressive Tax Planning Arrangements
Action Plan 12-Disclosure of Aggressive Tax Planning Arrangements: Clarity and comprehensibility Ability to balance additional compliance costs to taxpayers with the benefit obtained by the tax administration. Flexibility and dynamism: to allow…
Action Plan 6- Preventing Treaty Abuse Of BEPS [Latest Added]
Action Plan 6-Preventing Treaty Abuse: Protection Against Treaty Shopping: Treaty shopping means taking the benefit of any treaty by any person which is not meant for that person. Suppose as per India…
Action Plan 6- Preventing Treaty Abuse Of BEPS [Latest Added]
Action Plan 6-Preventing Treaty Abuse: Protection Against Treaty Shopping: Treaty shopping means taking the benefit of any treaty by any person which is not meant for that person. Suppose as per India…
Action Plan 5 – Counter Harmful Tax Practices Of BEPS
Action Plan 5-Counter Harmful Tax Practices Normally every country tax royalty on Intellectual property at lower rate. MNE’s normally develop Intellectual property in high tax jurisdiction but registered that Intellectual property in…
Action Plan 4- Interest Deductions And Other Financial Payments
Action Plan 4- Interest Deductions And Other Financial Payments Normally International Group taking loan or debt in High Tax Jurisdiction because I interest is deductible expenses & they can reduce their over…
Action Plan 4- Interest Deductions And Other Financial Payments
Action Plan 4- Interest Deductions And Other Financial Payments Normally International Group taking loan or debt in High Tax Jurisdiction because I interest is deductible expenses & they can reduce their over…
Action Plan 3 – Strengthen Controlled Foreign Company Rules:
Action Plan 3- Strengthen Controlled Foreign Company Rules: Controlled Foreign Company are corporate entities incorporated in Tax Haven countries & controlled directly or indirectly by Resident of higher tax jurisdiction. (Parent state)…
Action Plan 2- Effects Of Hybrid Mismatch Arrangements
Action Plan 2-Neutralise The Effects of Hybrid Mismatch Arrangements: Hybrid Mismatch Arrangements means exploits a difference in the tax treatment of an entity or an instrument under the law of two or…
Action Plan 1- Addressing The Challenges of The Digital Economy
Action Plan 1-Addressing the Challenges of The Digital Economy: Taxation Issues in E-Commerce: These new business models have created new tax challenges. The typical taxation issues relating to e-commerce are: the difficulty…
Analysis of Base Erosion and Profit Shifting (BEPS)
Base Erosion and Profit Shifting (BEPS): Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit sand mismatches in tax rules to make profits ‘disappear for tax purposes or…
