TaxTonic #25: India on MLI - A Surgical Analysis!
- Year of Publication: 2023
- ISBN: 0
Episode Duration:
110 minutes
Episode Background:
'TaxTonic', a 'subscriber only' thought leadership series, is Taxsutra's endeavour to consistently deliver top notch technical content to it's readers. The labyrinth of tax rulings on convoluted transactions keeps the world of taxation unpredictable and ever-evolving. This series will feature engrossing presentations, incisive analyses and a deep-dive by the tax experts on burning issues & controversies. So, gear up for a 'tonic' to chisel your tax mind and challenge your wit.
Speaker:
Mr. H. Padamchand Khincha (Chartered Accountant)
Moderator:
Mr. Sachin Sastakar (Chartered Accountant)
What shall the episode cover?
OECD/G20 Inclusive Framework came up with 15 Action Plans after exhaustive multilateral deliberations to counter Base Erosion & Profit Shifting (BEPS). The 15th Action Plan gave us a Multilateral Instrument (MLI) as a tool to implement the anti-BEPS measures. MLI is a novel and rather complex concept for the tax world that is habitual to unilateral or bilateral measures, but proved to be a masterstroke that effectively changed over 3000 treaties globally.
India deposited its position on MLI in June 2019 and included almost all the countries of the Inclusive Framework within its ambit, mostly from FY 2020-21 onwards. Notifications and reservations by different countries is a challenge against amending the existing DTAA and a bigger challenge is implementation and understanding the country-wise positions. In this TaxTonic's silver episode, Taxsutra brings the nuances of MLI for India’s Covered Tax Agreements (CTAs). This episode primarily covers:
1. Compatibility clauses' impact on Reservations & Notifications by India
2. Hierarchy of anti-abuse provisions within DTAA read with MLI
3. Hits & Misses with synthesized texts
4. Impact of few MLI articles on DTAA with India
5. Role of Conference of Parties (COP)
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
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- Year of Publication: 2023
- ISBN: 0
Episode Duration:
110 minutes
Episode Background:
'TaxTonic', a 'subscriber only' thought leadership series, is Taxsutra's endeavour to consistently deliver top notch technical content to it's readers. The labyrinth of tax rulings on convoluted transactions keeps the world of taxation unpredictable and ever-evolving. This series will feature engrossing presentations, incisive analyses and a deep-dive by the tax experts on burning issues & controversies. So, gear up for a 'tonic' to chisel your tax mind and challenge your wit.
Speaker:
Mr. H. Padamchand Khincha (Chartered Accountant)
Moderator:
Mr. Sachin Sastakar (Chartered Accountant)
What shall the episode cover?
OECD/G20 Inclusive Framework came up with 15 Action Plans after exhaustive multilateral deliberations to counter Base Erosion & Profit Shifting (BEPS). The 15th Action Plan gave us a Multilateral Instrument (MLI) as a tool to implement the anti-BEPS measures. MLI is a novel and rather complex concept for the tax world that is habitual to unilateral or bilateral measures, but proved to be a masterstroke that effectively changed over 3000 treaties globally.
India deposited its position on MLI in June 2019 and included almost all the countries of the Inclusive Framework within its ambit, mostly from FY 2020-21 onwards. Notifications and reservations by different countries is a challenge against amending the existing DTAA and a bigger challenge is implementation and understanding the country-wise positions. In this TaxTonic's silver episode, Taxsutra brings the nuances of MLI for India’s Covered Tax Agreements (CTAs). This episode primarily covers:
1. Compatibility clauses' impact on Reservations & Notifications by India
2. Hierarchy of anti-abuse provisions within DTAA read with MLI
3. Hits & Misses with synthesized texts
4. Impact of few MLI articles on DTAA with India
5. Role of Conference of Parties (COP)
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
