1. What are the common methods of valuing a company? As many of you have heard, valuation is an art and not an
a. What is tax automation and what are its benefits? Tax automation means standardization of tax processes/ope
>> Case of health crises situation/ contagious disease: a. Lawful grounds of the processing: Health data is a
There are several variants of robots existing in today’s world – some of them being autonomous, semi-auton
Is Crypto-Asset Reporting Framework (CARF) is a good approach to solve the issues related to decentralization
By Nupur Jalan and Gianmaria Favaloro Click here to download
The commentary on GLoBE rules and the separate publication on illustrative examples were released in 2022. Thi
The write-up mainly covers basics of cryptocurrency/NFTs and a broader overview of some tax considerations sur
By Nupur Jalan Click here to download the draft paper *This is pre-print version of the paper and cannot be ci
1. Background • More and more stakeholders have started demanding increased visibility over the details of t
What are Robin Hood taxes: These are small taxes (financial transaction taxation) levied on financial transact
1. Background Decentralised finance (DeFi) aims at democratising finance by replacing centralized financial in
Click here to view the slides
By Geatano Manzi, Nupur Jalan Published in book- 9º Congresso Brasileiro de Direito Tributário Internacional
The book Radical Markets: Uprooting Capitalism and Democracy for a Just Society discusses the concept in more
Many countries in Latin America have also implemented some or the other forms of unilateral digital tax levies
The OECD’s Pillar Two solution is designed to ensure Global Minimum Taxation through a set of interlocking r
1. Background Keyword advertising has become an important area in digital marketing. There have been several c
1. Background and ongoing developments Trademarks help to identify the goods and services and distinguish them
By Gaetano Manzi, Nupur Jalan, and Jose MarÃa Vargas-Machuca Reyes Click here to download the article
With the increase in the need for digital transformation and to improve the efficiencies, many organisation ar
NFTs are acting these days as a boost to support the creator economy, and the market of NFTs are skyrocketing.
NFTs or ‘Non-Fungible Tokens’ are digital files having a unique identity that is verified on a blockchain
*By Nupur Jalan Click here to download the article There has been much debate on the extent to which Articles
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Some countries are high on mineral resources but lack enough growth. With good policies, these countries may b
Authors: Julia Maria Martinez Tapia, Nupur Jalan This article discusses the application of data analytics tech
Author: N.Jalan The article aims to discuss the digital tax landscape in Asian countries, including briefly su
Authors: N. Jalan; E. Misquith-Tigdi In the past couple of years, countries across the globe have implemented
Book Chapter Authors: Steef Huibregtse, Nupur Jalan, Jasper Verkamman For full Chapter refer link
Authors: Nupur Jalan, Gaetano Manzi and Gert Greve Arcil Over time, the use of most favoured nation clauses ha
The paper analyses Africa’s digital tax landscape, analyze various unilateral measures, and examine some dig
Authors: Nupur Jalan, Elvira Misquith A comparability analysis forms the core of transfer pricing and involves
Digital economy taxation – Discussion on the existing developments, possiblealternatives and way forward Aut
Book chapter: Withholding Tax Provisions – A Compendium, YIN India
Click here to read the full submission
Discrimination means unequal treatment in similar and comparable situations. Article 24 of the Model Tax Conve
Citation: [2019] 105 taxmann.com 352 (Article)
Citation: [2019] 105 taxmann.com 56 (Article)
Citation: [2019] 105 taxmann.com 332 (Article)
Citation: [2019] 105 taxmann.com 332 (Article)
Submitted to Africa Tax Research Network
[2019] 104 taxmann.com 152 (Article) Click here to read the full article
The paper aims to describe the benefits and challenges arising from the establishment of such a data exchange
The importance of data for companies has taken a new limb in this era of rapid advancement of emerging technol
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Book chapter: Emerging International Taxation Landscape, Wolter Kluwer (2019)
Over the last couple of years, the government has taken multiple steps to revive the economy – from ease
The paper discusses the exchange of information and advancements surrounding it. Written in year 2015
The notion of value creation is gaining traction. Even the OECD emphasized aligning profit taxation witheconom
The Covid-19 pandemic seemed like a historic turning point like World Wars I and II and the Great Depression.
This article discusses an Arbitral Tribunal’s award under a bilateral investment treaty in the Cairn case re
Thin capitalization occurs when an entity is financed using a relatively high amount of debt compared with equ
The Lisbon International & European Tax Law Series Paper: Substantive Scope or Income Taxes covered by tax
Key takeaways: Often people have told me that we need to manage time to increase our productivity. However, this book lays down on the idea that one should ‘manage the attention’ for managing productivity. The mechanics suggested by the author to manage attention is to hyperfocus (i.e., to maximize productivity) and to scatter focus (i.e., [...]
Key takeaways The book’s primary focus is to reflect on the need to start with ‘WHY’ in all endeavou
In this article, the author examines bilateral investment treaties, noting the rise and decline in theirpopula
The report intends to present the valuation undertaken on a travel meta-search platform TripAdvisor Inc. Secti
Under existing laws and tax treaties of most countries, TP rules are predicated on the ALP. The principlerequi
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In Part 4, I have discussed Dual resident triangular case. In this part, i am focusing on fourth situation i.e
In Part 3, I have discussed Reverse PE triangular case. In this part, i am focusing on third situation i.e. Du
In Part 2, I have discussed PE triangular case. In this part, i am focusing on second situation i.e. Reverse P
In part 1, I have discussed some of the situations in which triangular cases arise. In this part, i am focusin
The aim of this article is to identify possible scenario’s of triangular cases. Often, situation arises in w
In part 5 of the series, I have discussed Article 24(4) which deals with deduction non-discrimination i
In part 4 of the series, I have discussed Article 24(3) which deals with PE non-discrimination in detail. In t
In part 3 of the series, I have discussed Article 24(2) which deals with stateless person in detail. In this p
In part 2 of the series, I have discussed Article 24(1) which deals with Nationality non-discrimination in det
In part 1 of the series, I have given an overview of Article 24 on Non-discrimination. In this part, I will di
<<The purpose of this series is to have discussion on non-discrimination clause of the bilateral tax tre
Various unresolved issues – Issues that are arising in context of Foreign tax credit (‘FTC’) are â€
Credit method (continued) Tax sparing credit method – Under this, taxpayer will get credit of the amoun
Credit method – Country of residence retains the right to tax the foreign income but credit is allowed
Bilateral tax credit – Relief provided pursuant to DTAA between the two countries are known as Bilatera
Unilateral tax credit – Section 91 of Income Tax Act, 1961 (‘Act’) enables its residents to avail unilat
Since, each nation have differenent rules of taxing persons, the same income may get taxed more than once (oft
Select jurisdictions CFC rules CFC legislation is adopted in many countries although with some differences. It
Example Where a resident(s) of Country A is able to influence or control an entity that is resident(s) of Coun
Overview of Controlled Foreign Corporation (CFC) rule – Controlled foreign company (‘CFC’) rul
Introduction Arm’s length principle (‘ALP’) was introduced a century ago to ensure proper allocation of
Article 9(1) of the MC states the ALP that is applicable to commercial and financial relations betweenassociat
I. Tesla’s open patent strategy Tesla’ per se open patent strategy[1] can be attributed to a wide
The modern innovative business models in this era of the digital data economy are giving rise to highly integr
I. What is a data ecosystem and why it matters 1. The origin of the term ecosystem Although there might b
Just imagine you being in a data conference throwing out the just cited definition. Probably you will rather l
The current era of confluence of data, storage, algorithms, and computational power has set the phase of creat
Games in general is interaction between two or more people where the outcomes of interactions depends on what
The views in all sections are personal views of the author.