Author: Ameet Baid, Pragya Bansal & Saahil Mehra, ASA
Cross-border transactions have gained momentum across geographies. Multinational enterprises (MNEs) are aggressively carving out ways and means to execute business operations in manner that yields maximum rewards. On one hand, the local tax laws are drafted such that they aim at extracting maximum tax revenue for the respective country, while on the other hand, the provisions of the treaty provide a cushion to the taxpayer(s), undue advantage of which is leveraged by the taxpayers – a concept known as “Treaty-Shopping”.
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