The difficulties of testing preparatory and auxiliary activities

Sanjeev Sharma

July 16 2020

Sanjeev Sharma, principal director of income tax (investigation) at the India Income Tax Department, considers how the ‘preparatory’ and ‘auxiliary’ test has become difficult to apply, despite amendments to the OECD and UN model tax treaties, as well as the MLI.

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Sanjeev Sharma

India Income Tax Department

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