International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Expert Analysis

lead
Direct Tax
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
February 11, 2026
features sponsored features special focus local insights
  • Latin America’s tax treaty network is undergoing serious reform as countries implement the BEPS project deliverables and incorporate these new strategies and frameworks into double taxation agreements (DTAs) to further the region’s business opportunities.
  • ‘Transparency’ is the latest term of art that has emerged from the OECD’s Action Plan with respect to its base erosion and profit shifting (BEPS) initiatives. But the obvious question that has consciously been ignored in the public domain is: where are the matching transparencies regarding determination of tax risks and identification of substantive issues by tax authorities upon commencement and conduct of an audit?
  • The Budget season is about to start in Asia. Ralph Cunningham believes finance ministers are likely to prioritise local or regional concerns rather than get involved in any deep discussions about base erosion and profit shifting.

Sponsored Features

Special Focus

Local Insights

Ad - shared