Tag: International Tax
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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.
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.
GAAR in India after a decade: credible deterrent or underused headline provision?
A decade after GAAR entered the statute book, India’s anti-avoidance rule looks less like a daily weapon and more like a quiet constraint on how aggressive planning gets priced.
Treaty Shopping After Tiger Global: When Substance Starts to Trump Form
Treaty shopping disputes in India are moving from form to substance. After Tiger Global, the real issue is no longer paperwork alone, but who actually controls income, risk, and exit.
