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)
Deferred Customs Duty for Manufacturers: EMI Scheme Takes Effect from 1 April 2026
In a significant move to ease working capital pressures for manufacturers, the Central Board of Indirect Taxes and Customs (CBIC), vide Ci...
-
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...
-
Section 68 -Cash credits Section 69 -Unexplained investments Section 69A - Unexplained money, etc Section 69B -Amount of investme...
-
An eminent concern within the GST framework pertains to the entitlement of Input Tax Credit (ITC) concerning expenditures associated with In...
-
The posting had been move to another website. Please click the link below to get the access of the same. https://taxofindia.wordpress....
-
There are certain changes in India's tax rules for TDS on payments made to non-residents. The Income Tax Act, 2025 ('ITA 2025'...
-
Recent judicial pronouncements across different forums have clarified several important aspects of Indian income tax law, particularly relat...
-
The overall effective tax rate of a U.S. multinational corporation may have significant impact on the value of its stock. Therefore, it ...
-
Ahmedabad Tribunal Special Bench has ruled that corpus distributed on dissolution of an offshore discretionary trust to resident Indian be...
-
The Income Tax department has been modified the Form No. 15G & 15G as per amended notification No. 11/2013 [F.NO.142/31/2012-SO(TPL)]/...
-
Did you come across many errors and mistakes while checking your CIBIL report status? Are you wondering how to clear yourself out of CIBIL ...
No comments:
Post a Comment