Introduction to Arbitration At present, the Mutual Agreement Procedure (MAP) resolves the tax issues arising from cross-border tax. It has been successful in its attempts to resolve tax matters brought by taxpayers to the competent authorities. But as per the OECD MAP statistics 2020, it is a long-drawn process. ArbitrationImpact of BEPS on ArbitrationScope of Arbitration … Continue reading Introduction to Arbitration

Principal Purpose Test | Paragraph 1 of Article 7 of MLI


BEPS Action 6 Report on Preventing the tax treaty benefits in inappropriate circumstances includes three alternative rules to address situations of treaty abuse. Firstly, a general anti-abuse rule (GAAR) is based on the principal purpose of transactions or arrangements. The second a simplified version of specific anti-abuse rules (SAAR), and the third a detailed version … Continue reading Principal Purpose Test | Paragraph 1 of Article 7 of MLI


Preferential Regimes as per the OECD


Forum for Harmful Tax Practices has reviewed multiple regimes to identify which system is harmful to the tax base of other jurisdictions. The focus of the review was to determine the regime which provided preference for the geographically mobile business income. Key Criteria for Identifying Harmful preferential tax regime Criteria for assessing whether the preferential … Continue reading Preferential Regimes as per the OECD