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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MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure