top of page
radhakishan rawal
CBDT Draft Report on PE Profit Attribution – A Different Angle
CBDT recently released a Report on Attribution of Profits to Permanent Establishment for public consultation. This report has generated...
radhakishan rawal
Conceptualizing the U.N. MLI
With the completion of the 22nd Session of the Committee of Experts on International Co- operation in Tax Matters (U.N. Tax Committee, or...
radhakishan rawal
Thoughts on the Fees for Technical Services ArticleIn the U.N. Model
The U.N. Model Double Taxation Convention Between Developed and Developing Countries does not contain a specific article dealing with...
radhakishan rawal
Eye Share: Rationalizing Application of Section 171 to Supply of Goods
The provisions of section 171 are operational with effect from July 1, 2017 in absence of any direction on the methodology for...
radhakishan rawal
Pillar 1: Who Should Be PayingThe Tax Bill?
The OECD’s pillar 1 solution does not replace the treaty framework that distributes taxing rights among countries. The amount A...
radhakishan rawal
Improve nexus rule for fair distribution of taxing rights to developing countries
One of the open issues for Pillar One in the discussion on the taxation of the digital economy is the nexus threshold, which would...
bottom of page