Thursday , June 11, 2026 |   06:21:09 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
I-T - Subscription-based access to journals, e-magazines or databases is not FTS, unless content is specifically rendered for user's individual requirements: ITAT (See Breaking News) TP - Revenue-neutral related party payments do not justify transfer pricing adjustment where there is no tax arbitrage: ITAT (See Breaking News) I-T - Payments made to foreign telecom operators for data transmission services outside India are not royalty under DTAA so as to trigger withholding u/s 195: ITAT (See Breaking News) TP - Persistent losses in three successive assessment years is sufficient ground for exclusion of comparable: ITAT (See Breaking News) TP - Failure to first issue a draft assessment order renders final assessment order invalid & without jurisdiction: ITAT (See Breaking News) I-T - Once established that assessee had sufficient explained foreign income & remittances are duly sourced from such income, consequent investment in immovable property cannot be deemed unexplained merely because certain payments were not fully verifiable at assessment stage: ITAT (See Breaking News) DTAA - Payment made for offshore supply cannot be construed as FTS in absence of make available clause or no transfer of technology: ITAT (See Breaking News) TP - Capital contribution to wholly owned subsidiary cannot be re-characterized as loan in absence of debt-like features: ITAT (See Breaking News) I-T - Internal allocation of expenditure by one branch/head office to another branch of same enterprise cannot be disallowed u/s 40(a)(i) in absence of payment so as to trigger Sec 195: ITAT (See Breaking News) I-T - Non-obstante clause u/s 144C(13) does not exclude operation of Sec 153 as whole: ITAT (See Breaking News) Industrial dole-outs reach a new peak since global financial crisis: OECD (See TII Brief) I-T - Time limit prescribed u/s 153 has to be adhered to and both Section 144C and 153 are mutually inclusive and interdependent: ITAT (See Breaking News) I-T - Presence of notwithstanding clause in Section 144C(13) would not exclude operation of Section 153: ITAT (See Breaking News) I-T - Receipts from sale of Renewable Energy Certificates are capital receipts and are not taxable as revenue income: ITAT (See Breaking News) TP - Section 94B applies only when debt is from non-resident AE and no corresponding restriction exists for resident AE borrowings: ITAT (See Breaking News) TP - Functional dissimilarity, turnover filter, and abnormal profit calls for exclusion of comparable: ITAT (See Breaking News) TP - TPO cannot question commercial expediency once expenditure is shown to have been incurred for business purposes; assessee must nevertheless establish that services were indeed rendered: ITAT (See Breaking News) TP - Comparables selected in previous assessment years need to be included in current year as well, in identical facts & circumstances: ITAT (See Breaking News) TP - Adjustment on account of interest paid on NCDs cannot be made by ignoring internal CUP: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

Draft BEPS Action 6 to Prevent Treaty Abuse: OECD seeks public comments
By TII News Service
May 25, 2015 , Paris

    
OECD has invited public comments on a revised discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent Treaty Abuse) of the Action Plan on Base Erosion and Profit Shifting (BEPS).

On 21 November 2014, the OECD released a discussion draft that identified 20 different issues to be addressed as part of the follow-up work mandated by the September 2014 Report on Action 6. At its March 2015 meetings, Working Party 1 on Tax Conventions and Related Questions continued its work on these issues in the light of the comments received, agreed on how to address the majority of these issues and discussed new proposals related to some issues.

This new discussion draft reflects the conclusions and proposals that resulted from that meeting and on which the Committee on Fiscal affairs is now inviting comments. The discussion draft and the comments received on it will be discussed at the Working Party 1 meeting of 22-26 June 2015, when the Working Party will be asked to produce a final version of the Report on Action 6 that will take into account the conclusions of the follow-up work done on the issues identified in the November 2014 discussion draft.

Comments should be sent by 17 June 2015 at the latest (no extension will be granted) and should be sent by email to taxtreaties@oecd.org in Word format (in order to facilitate their distribution to government officials). They should be addressed to Marlies de Ruiter, Head, Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA.

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.