On October 5 2015, the OECD released its final reports under the BEPS project, which were presented to the G20 finance ministers on October 8 2015. Action 6 identifies tax treaty abuse and, in particular, treaty shopping, as one of the most significant sources of BEPS concerns. Pritin Kumar, Vishal Palwe and Heta Jhaveri of Deloitte provide an update on action to counter treaty abuse, from an Indian perspective.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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