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BEPS Thought leadership
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Multilateral Instrument: Analysis and India perspective
The MLI is a big step in the BEPS implementation process. The provisional list of reservations and notifications made by India and by other countries, has provided insights on how Indian tax treaties will shape up in the BEPS world. It needs to be seen if India makes any further changes in the provisional list of reservations and notifications.
BEPS Action 13 – India implementation
The final rules on CbC reporting and Master File requirements in India are significantly aligned with BEPS Action 13 guidance, reflecting India’s commitment to global consistency. It is imperative to mention that there are various aspects of the rules that will have specific India implications and will also need clarifications and additional information. The final rules incorporate various clarificatory amendments to the draft rules and there are not many noteworthy modifications to the draft rules.
Base Erosion and Profit Shifting (Beps) Analysis and India Perspective
Launched in 2017, this report focuses on reinforcing substance requirements in international standards to ensure alignment of taxation with the location of economic activity and value creation: There are aspects to prevent tax treaty abuse (i.e. treaty shopping), strengthen rules relating to creation of a permanent establishment for taxation in the source country, ensuring transfer pricing outcomes are in line with value creation in relation to intangibles, etc. This publication analyses key issues around BEPS as well as outlines the Indian perspective in relation to these issues.
Base Erosion and Profit Shifting (BEPS) Analysis and India Outbound Perspective
Launched in 2017, this report focuses on reinforcing substance requirements in international standards to ensure alignment of taxation with the location of economic activity and value creation: There are aspects to prevent tax treaty abuse (i.e. treaty shopping), strengthen rules relating to creation of a permanent establishment for taxation in the source country, ensuring transfer pricing outcomes are in line with value creation in relation to intangibles, etc. This publication analyses key issues around BEPS as well as outlines the Indian perspective in relation to these issues from an outbound perspective.
