United Nation releases 2017
update of the Model Double Taxation Convention between Developed and Developing
Countries; The UN Model Convention introduces new article 12A on 'fees
for technical services' (the article which is absent in OECD's convention); The
2017 update also incorporates some of the language of the BEPS project;
The 2017 UN Model Convention introduces a new general anti-abuse
rule in article 29(9); A note released by the UN Committee states that
"[the new rule] together with the specific anti-abuse rules included in
tax treaties, is intended to prevent transactions and arrangements from being
granted treaty benefits in circumstances where granting such benefits would be
contrary to the object and purpose of the Model Convention"; Article
4 is modified to include a new tie-breaker rule for determining the treaty
residence of dual-resident persons other than individuals and Article 5
is modified to prevent the avoidance of permanent establishment status; The
2017 Model was released during the 16th session of The Committee of Experts on
International Cooperation in Tax Matters of United Nations held this week at
New York
Subscribe to:
Post Comments (Atom)
Bombay HC Clarifies That Genuine Bad Debt Write-offs Need Not Fail for Accounting Technicalities
Businesses often find themselves in a peculiar position when a customer default turns into a prolonged dispute. Even where recovery procee...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
Issue before the Income-tax Appellate Tribunal (ITAT) Whether the phrase “paid up capital and general reserves” should be defined as “Ne...
-
Introduction Employee welfare is a cornerstone of corporate responsibility, and gratuity forms a critical part of the social security benefi...
-
Sr No Due Date Related to Compliance to be made 1. 11.06.2026 GST ...
-
In the complex landscape of India’s Goods and Services Tax (GST), the tax treatment of non-compete fees has emerged as a critical area f...
-
Selling a property can trigger a significant tax liability in the form of capital gains tax. However, the Income-tax Act, 1961, allows you...
-
Capital gains taxation on immovable property under the Income-tax Act, 1961 often turns on a deceptively simple question: when is a proper...
-
Tax Deducted at Source (TDS) is generally not applicable to interchange fees, payment gateway charges, or the Merchant Discount Rate (MDR)...
-
The newly enacted Income Tax Act, 2025, marks a significant step toward simplification by consolidating multiple presumptive taxation sche...
-
In a significant victory for multinational enterprises and foreign portfolio investors, the Delhi bench of the Income Tax Appellate Tribun...
No comments:
Post a Comment