India Tax ForumIndia Tax ForumTo bring parity in the tax treatments for the Organisation for Economic Cooperation ad Development (OECD) member nations, the concept of Most Favoured Nation (MFN) is prevalent under International tax laws. Central Board of Direct Taxes has issued clarifications around the applicability of MFN clause of Indian Double Taxation Avoidance Agreements (DTAAs or treaties) with OECD member states (or countries). Please access the CBDT circular here.
OECD has released Draft Rules for Nexus & Revenue Sourcing as a part of multi-stage public consultation for Amount A of Pillar One. Click here to read the OECD Press Release and also to download the public consultation document.
The OECD has published detailed rules to assist in the implementation of a landmark reform to the international tax system, which will ensure Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023. The Pillar Two model rules provide governments a precise template for taking forward the two-pillar solution to address the tax challenges arising from digitalisation and globalisation of the economy agreed in October 2021 by 137 countries and jurisdictions under the OECD/G20 Inclusive Framework on BEPS. Please refer to the rules along with the press release here.
CBDT, vide Circular No. 20 of 2021 has issued much awaited guidelines on scope of Sections 194-O(4), 194Q(3) and 206C(1-I). Click here to read and download the CBDT Circular.
OECD/G20 Inclusive Framework on BEPS releases fifth annual Peer Review Report assessing 131 jurisdictions’ progress on exchanging information on tax rulings, in accordance with Action 5, for the calendar year 2020. This is the first review taking place under the renewed peer review process, agreed upon by the member nations last year, with a view to further enhancing and consolidating transparency in relation to the issuance of tax rulings; Click here to read and download the Annual Peer Review Report.