India follows the dualist model in its legal system wherein international treaties are not automatically incorporated in domestic law but require transformation through implementing legislation. The equalization levy was brought in the statute books in India in 2016 and its scope substantially...

The Multilateral Instrument (MLI) is a complex document that impacts the double tax treaties in myriad ways. The data file attempts to decode the modification of India's tax treaties by capturing the country-positions of India and its treaty partners and explaining the operation of the specific...

This report was drafted with a focus on India for IFA's general report on the same subject and was published by IFA in July 2020 as part of the 'Cahiers de Droit Fiscal International' No. 105a in connection with 2020 IFA Congress in Cancun, Mexico. India has actively participated in the Base...

In the ever-growing tide of international tax literature, the issue which figures the most is prohibiting/relieving double taxation. It is only ironical that this issue which finds itself as the center-stage of international tax arena is not just neglected but instead more-often-than-not...

This article analyses critically the interpretation of the MFN clause in the NL-India tax treaty. It sounds a note of caution against following the Delhi High Court's decision in the case of Concentrix

The Government of India submitted the ‘Direct Taxes Code' Bill, 2010 the Parliament in August, 2010. The Code, expected to come into force from the next financial year i.e. 1st April 2012, is not just a regular amendment but replaces all the existing direct tax laws in India. The drafters have...

The Union Finance Minister presented before the Indian Parliament the Budget for Financial Year 2022-23 on February 1, 2022. Amidst the various tax proposals introduced in the Budget, the most talked about were the proposals to tax crypto-assets. Of course one can expect certain changes (by way...

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...