BEPS, Digitalization, Equalization levy, India, International Tax Law, MNE Profits, OECD, Permanent Establishments, Tax Avoidance, Tax Policy, Tax Treaties, Uncategorized, United Nations

(Advocate)/ /Leave a comment

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 as part of its 15-point Action Plan to tackle base erosion and profit shifting. The Indian government, too, introduced two key…

BEPS, India, OECD, Principal purpose test

(Advocate)/ /Leave a comment

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 nothing can be said to be certain, except death and taxes.” Franklin was right then and he is right now. However, there is one more commonality…