A global tax framework that seeks to counter treaty abuse, signed recently by India, may lead to more litigation between tax authorities and overseas investors as its interpretation could become subjective. Also, whenever it clashes with the domestic norms to check tax avoidance, called the General Anti-Avoidance Rules (GAAR), higher chances are that the former may prevail even as the latter is more clearly defined.
Last month, India ratified the multilateral instrument (MLI) to prevent base erosion and profit shifting (BEPS). BEPS is the framework by OECD to prevent tax evasion by ...
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