Introduction to Arbitration

 

https://media.rss.com/taxbeech/feed.xml 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. https://www.youtube.com/watch?v=j7uX9ZdUgG0&list=PLYkyV5logMkUCUKMAkwesbgVNc7Z2K-9X&index=1 ArbitrationImpact of BEPS on ArbitrationScope of Arbitration … Continue reading Introduction to Arbitration

Everything about Triangular Cases

 

We have repeatedly discussed how corporate and multinational entities have creatively used the tax treaties to reduce their overall tax liabilities. One such measure is a typical “Triangular case” where three countries are involved, the State of residence of the entity, the State of the Source, and the State where the Permanent establishment is resident … Continue reading Everything about Triangular Cases

Introduction to Article 23A / 23B of the OECD Model Tax Convention

 

All our previous posts were about tax jurisdiction and “whom” to pay tax. But today’s post is about how “not pay tax” in two countries. Yes. Today’s post is about the mitigation of double taxation. Let’s dig deep. Of all the available methodologies of elimination of double taxation, the OECD Model tax convention has provided … Continue reading Introduction to Article 23A / 23B of the OECD Model Tax Convention

Analysis of operations and effects of the method of elimination of double taxation.

 

In our previous post, we had an overview of the two principles used for eliminating double taxation. For understanding the policies adopted in Article 23A and 23B of the OECD Model Tax Convention, we need to have a better understanding of the principles and classifications involved. Today we will understand in detail the functioning of … Continue reading Analysis of operations and effects of the method of elimination of double taxation.