The European Commission has unveiled a proposal that aims to improve the savings taxation directive to ensure the taxation of interest payments which are channelled through intermediate tax-exempted structures. In a speech last month, reported in International Tax Review, Láslo Kovács, commissioner for taxation said the original tax directive contained loopholes that facilitated tax evasion.
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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