MFN clause after Nestlé: treaty shield or drafting illusion?
MFN clause disputes in India are no longer a technical footnote. Recent rulings, a 2025 tribunal order, Switzerland’s reset and France’s 2026 rewrite show why treaty parity now turns on wording, timing and notification discipline.
SaaS Tax and India’s Cross-Border Misfit: Royalty, FTS, Business Profits—or a Broken Taxonomy?
Cross-border SaaS tax in India still relies on old labels—royalty, FTS, and business profits. That mismatch is now raising withholding risk, pricing uncertainty, and treaty disputes.
Beneficial ownership: how much commercial substance does treaty relief really need in 2026?
Beneficial ownership is no longer a box-ticking treaty concept. In 2026, Indian treaty relief turns on whether the recipient truly controls, retains, and bears the income.
Remote Work Permanent Establishment Risk: Has Practice Caught Up With Post-Pandemic Delivery?
Remote work permanent establishment risk now turns on people functions, home-office facts, agent behaviour and treaty thresholds - not just branches, leases or frequent travel
Equalisation levy: is it living on borrowed time in a Pillar One–Pillar Two world?
Equalisation levy may be off the statute book prospectively, but its repeal says as much about OECD pressure and compliance friction as it does about digital tax reform.
