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Taxing Unrealized Capital Gains: A Progressive Taxation Measure or An Irrational Taxing Adventure
With the growing trends of Multinational Companies employing Debt financing instead of equity financing, not only the capital structure of the Companies were distorted, but also the problem of profit shifting and base erosion occurred. Even though the origin of the implementation of thin capitalisation rules in India can be traced back to OECD guidelines, there were a handful of nations that had implemented the rule even before the OECD had acknowledged the problem. What has
Rishi A. Kumar
Jul 428 min read
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Assignment of Leasehold Rights in India: Assessing Taxability under the GST Regime
Taxing assignment of leasehold rights under the GST regime has been an unsettled issue, intertwined within considerations of indirect taxation and property law, for a significantly long time. Property law theorists categorise assignment of leasehold rights as a sale of immoveable property, after delving into the legal meaning of the term ‘immoveable property’ which also includes ‘benefits arising out of such property.’ Further, sale of immoveable property cannot reasonably be
Lauren Prem
Jun 1524 min read
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Assurance at Stake: Handling the Difficulties of the PPT in light of BEPS Action 6 and the MLI
In an era long before WhatsApp and other social media platforms took over communication, pigeons held a place of honor for the vital messages they carried. Let us rewind to the year 1789, when Benjamin Franklin penned to Jean-Baptiste Leroy (a famous scientist), famously stat...
Deepesh Tapariya
Jun 1532 min read
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