The 2013 Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan) identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Jacques Sasseville and Edward Barret look at the work done to counter the unintended uses of tax treaties in an international context.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties