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International Tax

  • Navigating the Labyrinth of ‘Make Available’ in Context of Global Cost Allocation
    Globally, business groups have a model in terms of which one of the group entities would incur cost in respect of certain items or activities for and on behalf of the entire group and allocate the costs to each ofthe group constituents. Variations include cost allocation for support provided by…
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  • Preamble to Multilateral Instrument & Treaty Shopping
    Foreign Investments in India are routed through different countries either for business reasons or for tax benefits depending upon the bilateral treaty between the respective countries. For many years it has been established that tax evasion is illegal; tax avoidance is always a matter of debate and tax planning is…
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  • MASTER CLASS IN MASTERCARD RULING
    All of us purchase goods and services and use our debit card or credit card at the vendor outlet. In a few seconds, the transaction is authenticated and the payment process is complete.
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  • Equalisation Levy
    The growth of e-commerce and digital economy has created MNCs who operate from different jurisdictions and are not discharging tax on income generated in a country as they do not have a permanent establishment and advantages are taken through multiple treaties.
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  • Sec.206AA and DTAA - Feb 2016
    Section 206AA provides that any person entitled to receive income or amount on which tax is deductible under Chapter XVIIB shall furnish his permanent account number (PAN) to the person responsible for deducting such tax.
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