Tag Archives | Anti-Avoidance Measures

Difference between Tax Evasion and Tax Avoidance

The upcoming discussion will update you about the difference between tax evasion and tax avoidance. Difference # Tax Evasion: Tax evasion implies an intention to avoid payment of tax where there is actual knowledge of liability. It usually involves deliberate concealment of the facts from the revenue authorities, and is illegal. Evasion does not generally […]

Judicial Anti-Avoidance Doctrines

In this article we will discuss about:- 1. Introduction to Anti-Avoidance Doctrines 2. Common Law for Anti-Avoidance Doctrines 3. Civil Law 4. Various Countries. Introduction to Anti-Avoidance Doctrines: International tax avoidance is also affected by the interpretations of judicial bodies in various countries. The practice varies considerably. The Courts in many countries take a literal […]

Anti-Treaty Shopping | International Taxation

In this article we will discuss about:- 1. Introduction to Anti-Treaty Shopping 2. Impact 3. OECD Model Treaty and Commentaries 4. Beneficial Ownership Requirement 5. Various Countries 6. Comments. Contents: Introduction to Anti-Treaty Shopping Impact of Treaty Shopping Treaty Shopping under the OECD Model Treaty and Commentaries Beneficial Ownership Requirement Anti-Treaty Shopping in Various Countries […]

Determination of Arm’s Length Price | International Taxation

The following points highlight the top two methods for the determination of arm’s length price. The methods are: 1. Traditional Transaction Methods 2. Transactional Profit Methods. 1. Traditional Transaction Methods: (a) Comparable Uncontrolled Price Method (“CUP”): The price is based on the sale or purchase from an uncontrolled party, or from an uncontrolled transaction of […]

Transfer Pricing: Meaning, Transactions and Guidelines

In this article we will discuss about:- 1. Meaning of Transfer Pricing 2. Transactions Involving Transfer Pricing Issues 3. OECD 4. Guidelines 5. Domestic Tax Law 6. Tax Treaties 7. Various Countries. Contents: Meaning of Transfer Pricing Transactions Involving Transfer Pricing Issues OECD and Transfer Pricing Guidelines on Transfer Pricing Transfer Pricing under Domestic Tax […]

Top 6 Anti-Avoidance Measures for Taxation

The following points highlight the top six anti-avoidance measures for taxation. The measures are: 1. Exchange of Information 2. Transfer of Tax Residence and Exit Taxes 3. Exchange Controls 4. Branch Profits Tax 5. Use of Tax Havens 6. Anti-EC Directive Shopping Legislation. 1. Exchange of Information: The controls over international tax avoidance and evasion […]

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