The OECD has published a 42-page Country-by-Country Reporting Implementation Package this week, which consists of model legislation, a multilateral competent authority agreement on the exchange of country-by-country reports, two other competent authority agreements, one based on a double tax convention, the other based on a tax information exchange agreement (TIEA), and a confidentiality and data safeguards questionnaire.
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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