The Indian tax authorities recently held in Ardex that taking advantage of a tax treaty by itself is not objectionable treaty shopping. Not every transaction that seeks to benefit from a treaty is equivalent to tax evasion. Ravishankar Raghavan of Majmudar & Co discusses the ruling and provides a few steps to demonstrate substance in intermediary locations including Mauritius.
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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.