OECD releases 2019 MAP statistics and calls for stakeholder input on the BEPS Action 14 review on Tax Certainty Day

18/11/2020 – As part of the BEPS Action 14 minimum standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms, the OECD releases today the latest mutual agreement procedure (MAP) statistics covering 105 jurisdictions and almost all MAP cases worldwide. The 2019 MAP Statistics* and the 2019 MAP […]

Common strategies used by Non-Resident for artificially avoidance of Permanent Establishment that government is trying to stop

Avoidance of Permanent Establishment status of Non-Residents was made through various arrangements. Company structures their business in way that status of Permanent Establishment can be artificially avoided. Government observed that certain common strategies were used to circumvent the definition of Permanent Establishment. Changes to the definition of Permanent Establishment were utmost importance. This task was[…..]

Analysis of Section 172 applicable on Profit of foreign Shipping Company

1. Introduction of shipping business India has a coastline spanning 7517 km with 13 major ports and about 200 small ports. According to the Ministry of Shipping, around 95 per cent of India’s trading by volume and 70 per cent by value is done through maritime transport. About 90% of India sea cargo is handled[…..]

Limitation of interest deduction under section 94B (Thin Capitalization) under the income tax act 1961

Many countries limit the amount of interest expenses of multinational companies (MNC). An enterprise who has borrowed capital in form of loan from its associate enterprises can claim deduction of interest paid and payable to associated enterprises. Foreign companies have several models to infuse capital in its associated company situated in another country. Some may[…..]