The author is Shourya Singh, a Second Year B.A. LL.B. Student from National Law University Jodhpur. Keywords: Digital Taxation Introduction For close to a decade, the United States has cast itself as the world's loudest opponent of taxing the digital economy. When France, the UK, Spain, and Italy rolled out Digital Services Taxes (DSTs) on Big Tech between 2018 and 2020, Washington answered with Section 301 investigations and the threat of retaliatory tariffs. When Canada fin

The evolution of taxation of equity share buybacks in India has undergone a tumultuous journey over the recent years giving rise to a tangle of consequences that have become evident in practice. The latest Infosys buyback, priced at ₹1,800 per share with an 18% premium over the market rate is a glaring example of the challenges embedded in the legal framework evolved after the Finance Act (“FA”) amendment of 2024 which deemed the entire buyback consideration as dividend incom

In the 21st century, the world has witnessed unprecedented globalisation, with many MNCs venturing into global investments and generating substantial revenue. This international context is crucial to understanding the dynamics of Double Taxation Agreements and the Mutual Agreement Procedure (MAP) for resolving tax disputes, which aim to prevent Double Taxation.[1] However, there are drawbacks within MAPs due to firstly(i) the duration of time it took; secondly(ii) there w