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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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems