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Radhakishan Rawal’s Analysis of the Finance Act, 2020 and More
Key features · Indian approach to tax digital economy · TDS on Platform sellers (section 194-O) · Equalisation Levy · Amendment to tax residency provisions · Significant Economic Presence (Explanation 2A) · Taxation of Advertisement and data (Explanation 3A) · APA/SHR framework for attribution of profits · Amendment to section 90 · Synthesised Text of tax treaties · Triangular cases
Radhakishan Rawal’s Analysis of the Finance Acts of 2019 and More
About the book This book contains detailed analysis of some of the key provisions of the Finance Acts passed during the year 2019 i.e. Finance Act, 2019 and Finance (No.2) Act, 2019. The book aims at identifying various direct and indirect tax issues arising from the newly inserted provisions in the Income Tax Act, 1961 as well as the Goods and Services Tax Act, 2017. The book also contains a detailed chapter on Secondary Adjustment. The key direct tax issues analysed in this book are related to sections 9(1)(viii), section 79, section 92CE, section 115UB, section 194N, section 194DA and provisions related to International Financial Services Center (IFSC) of the Income Tax Act, 1961. Additio...
Radhakishan Rawal’s Analysis of the Finance Act, 2021 and More
About this book This book contains detailed analysis of some of the key provisions of the Finance Act, 2021 with the objective of identifying various issues arising from the newly inserted provisions in the Income Tax Act, 1961. This book also captures the recent development in the world of international taxation. This includes UN tax developments and a very simple explanation of working of OECD Inclusive Frameworks Pillar One and Pillar Two blueprints, which are too complex and lengthy documents. From GST perspective, the book contains certain recommendations for rationalization of anti-profiteering provisions. The book also contains a Concept Paper on UN MLI presented by the author to the ...
The Taxation of Permanent Establishments
This book's principal theme is the taxation of permanent establishments (PEs), taking as its starting point the OECD model convention on the avoidance of double taxation, and examining how the Indian courts and India's law-makers have interpreted the rules governing attribution of profits. Chapters include: taxation of business profits; para 1 of article 7; force of attraction rule; para 2 of article 7; profits from transactions with self; para 3 of article 7 OECD and UN Model; para 4 of article 7; para 5 of article 7; para 6 & 7 of article 7 OECD Model, other paras of US Model and other provisions of article 7; para 2 of article 3; approaches for ascertaining income under the Income Tax Act; profits attributable to business operations in India; methods of profits attribution; effectively connected - PE and dividend, interest, royalties, fees for technical services, other income; PE and immovable property; PE and capital gains; PE and non-discrimination; service PE; PE and return filing requirements; taxation of a liaison office as PE; scope of option under section 90(2); and summary of OECD duscussion drafts.
Taxmann’s Transfer Pricing – A Compendium | Collection of incisive & in-depth articles on transfer pricing covered in 2800 Pages by 150 Experts in the form of 75 Articles | Set of 2 Volumes
CTC’s Transfer Pricing – A Compendium is a collection of incisive & in-depth articles on transfer pricing, authored by recognised experts in the field. This book promises to provide the necessary guidance and support to fellow professionals to understand the intricate issues, which have always remained contentious and challenging. The current edition of the compendium is updated, incisive, and covers a broader range of topics. Like its previous edition, this book promises to be another handy tool for the following: • Tax Professionals both in India and Overseas • Judiciary and Tax administrators • Readers who want a useful reference point, both for technical analysis and for unders...
The Global Minimum Tax | Selected Issues on Pillar Two
Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́...
International Tax Aspects of Sovereign Wealth Investors
An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of ...
Permanent Establishments
Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in Ju...
Tax Treaty Dispute Resolution
Stakeholders in the international taxation community agree that existing dispute resolution processes are in serious need of improvement, and a global consensus must be achieved. This book offers a potential restructuring of the tax treaty dispute resolution system based on a comparative analysis of the dispute resolution mechanisms under tax treaties, as prescribed in the OECD and UN models, on the one hand, and the UN Law of the Sea Convention (LOSC) on the other. This comparative study is the first of its kind and is premised on certain key geopolitical similarities that underpin the international tax regime (ITR) and the law of the sea regime while taking into consideration the differenc...
Double non-taxation and the use of hybrid entities
The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific ta...
