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  • Valuation

Valuation of digital businesses – Q&A

1. What are the common methods of valuing a company? As many of you have heard, valuation is an art and not an

Tax automation – Some questions

a. What is tax automation and what are its benefits? Tax automation means standardization of tax processes/ope

GDPR and processing of health related data – Case study

>> Case of health crises situation/ contagious disease: a. Lawful grounds of the processing: Health data is a

Should robots be granted legal personhood/ citizenship?

There are several variants of robots existing in today’s world – some of them being autonomous, semi-auton

Crypto Assets: Crypto asset reporting framework and some open questions

Is Crypto-Asset Reporting Framework (CARF) is a good approach to solve the issues related to decentralization

Allocation of profits in the digital economy era: is Pillar 1 a
solution, or is it more of a compromise?

By Nupur Jalan and Gianmaria Favaloro Click here to download

Pillar 2- Computation of GloBE Income or Loss

The commentary on GLoBE rules and the separate publication on illustrative examples were released in 2022. Thi

The taxation of crypto assets – Introduction and overview of key concepts

The write-up mainly covers basics of cryptocurrency/NFTs and a broader overview of some tax considerations sur

India – Taxation of Virtual Digital Assets

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

ROBIN HOOD taxes – Can similar taxes be levied on crypto based trading?

What are Robin Hood taxes: These are small taxes (financial transaction taxation) levied on financial transact

Decentralised finance (DeFi) transactions- Certain tax implications

1. Background Decentralised finance (DeFi) aims at democratising finance by replacing centralized financial in

Non-Fungible tokens – Case study (Transfer pricing implications)

Click here to view the slides

Recent Developments on the Application of the Most Favoured Nation Clauses in Tax Treaties – The Indian Case Study

By Geatano Manzi, Nupur Jalan Published in book- 9º Congresso Brasileiro de Direito Tributário Internacional

Web3 and collaborative tax technology solutions

Click here to read the full blog

Harberger taxes – Does it have future?

The book Radical Markets: Uprooting Capitalism and Democracy for a Just Society discusses the concept in more

Digital tax landscape in Latin American countries

Many countries in Latin America have also implemented some or the other forms of unilateral digital tax levies

International Tax Reform and Its Effect on Digital Sovereignty

The OECD’s Pillar Two solution is designed to ensure Global Minimum Taxation through a set of interlocking r

Google AdWords: Use of competitors’ brand name – Legal implications

1. Background Keyword advertising has become an important area in digital marketing. There have been several c

Metaverse and trademark rights

1. Background and ongoing developments Trademarks help to identify the goods and services and distinguish them

Legal Status of the OECD Commentary: Comparative Analysis on Status Quo and Future Considerations Through MLI and OECD’s Two-Pillars Solution

By Gaetano Manzi, Nupur Jalan, and Jose María Vargas-Machuca Reyes Click here to download the article

Enterprise Resource Planning Implementation Project – Certain contract considerations

With the increase in the need for digital transformation and to improve the efficiencies, many organisation ar

NFTs – Its growing popularity and commercialization

NFTs are acting these days as a boost to support the creator economy, and the market of NFTs are skyrocketing.

NFTs and copyright issues

NFTs or ‘Non-Fungible Tokens’ are digital files having a unique identity that is verified on a blockchain

Dichotomy on the Applicability of Article 9(1) and Article 24(4) of the Model Convention to the Thin Capitalization Rules

*By Nupur Jalan Click here to download the article There has been much debate on the extent to which Articles

The courage to be disliked – Book by Ichiro Kishimi & Fumitake Koga

Click here to read more

The Leadership Challenges – Book by James M. Kouzes & Barry Poswer

Click here to read more

Resource taxation: Benchmarking commodity transactions

Some countries are high on mineral resources but lack enough growth. With good policies, these countries may b

An approach to BEPS risk assessment: Applying data analytics techniques to country-by-country reporting data

Authors: Julia Maria Martinez Tapia, Nupur Jalan This article discusses the application of data analytics tech

An analysis of diverse unilateral digital tax measures in Asian countries

Author: N.Jalan The article aims to discuss the digital tax landscape in Asian countries, including briefly su

What is the road ahead for unilateral digital tax measures

Authors: N. Jalan; E. Misquith-Tigdi In the past couple of years, countries across the globe have implemented

Treating Tax Relevant Data as a Strategic Asset by the in-house tax department

Book Chapter Authors: Steef Huibregtse, Nupur Jalan, Jasper Verkamman For full Chapter refer link

Most Favoured Nation clauses in tax treaties: comparative analysis and main issues

Authors: Nupur Jalan, Gaetano Manzi and Gert Greve Arcil Over time, the use of most favoured nation clauses ha

The Impact of Unilateral Digital Taxes in Africa

The paper analyses Africa’s digital tax landscape, analyze various unilateral measures, and examine some dig

Comparability adjustments and need for digital data intensity adjustment

Authors: Nupur Jalan, Elvira Misquith A comparability analysis forms the core of transfer pricing and involves

Emerging contours of Tax Risk Management

Click here to read the full article

Digital economy addendum

Digital economy taxation – Discussion on the existing developments, possiblealternatives and way forward Aut

Digital economy – New profit allocation and nexus approach

Read more

Tax Implications in Case of Permanent Establishment and No Permanent Establishment’

Book chapter: Withholding Tax Provisions – A Compendium, YIN India

Inputs on Public consultation document for Unified Approach

Click here to read the full submission

Inputs on Public consultation document for Pillar 2

Click here to read the full submission

Non-discrimination clause in tax treaties – Select issues and recent developments

Discrimination means unequal treatment in similar and comparable situations. Article 24 of the Model Tax Conve

Terms not defined in the tax treaty – How to derive its meaning?

Citation: [2019] 105 taxmann.com 352 (Article)

Overview of Singapore tax system

Citation: [2019] 105 taxmann.com 4 (Article)

Scope and Efficacies of Double Taxation Avoidance Agreements

Citation: [2019] 105 taxmann.com 56 (Article)

Foreign tax credit – Mechanism and issues surrounding it

Citation: [2019] 105 taxmann.com 332 (Article)

Taxation of the digital economy – Addressing the developments encircling it

Citation: [2019] 105 taxmann.com 332 (Article)

Anti-abuse rules – GAAR and PPT

[2019] 105 taxmann.com 327 (Article)

Digitalisation and the Potential Impact on the African Tax Landscape – An Indian perspective

Submitted to Africa Tax Research Network

Applicability of bilateral tax treaties in triangular cases

[2019] 104 taxmann.com 152 (Article) Click here to read the full article

Data as taxes – A blueprint for technical, institutional, and Normative framework for the data economy to pay taxes in data

The paper aims to describe the benefits and challenges arising from the establishment of such a data exchange

How to benchmark data transactions for transfer pricing

The importance of data for companies has taken a new limb in this era of rapid advancement of emerging technol

Comments on Public consultation document on the tax challenges of digitalisation to OECD

Click here to read the document

Multilateral Instruments – Is it a game-changer for India

Book chapter: Emerging International Taxation Landscape, Wolter Kluwer (2019)

Economic times – Budget 2018: An opportunity to realign India’s corporate tax regime

Over the last couple of years, the government has taken multiple steps to revive the economy – from ease

Exchange of Information and its advancement

The paper discusses the exchange of information and advancements surrounding it. Written in year 2015

Analysing Value Creation and Value Chain of Data Businesses

The notion of value creation is gaining traction. Even the OECD emphasized aligning profit taxation witheconom

COVID 19: Impact on economy and international tax

The Covid-19 pandemic seemed like a historic turning point like World Wars I and II and the Great Depression.

The Cairn Arbitration Award: Retrospective Taxation of Indirect Share Transfers in India Breaches Bilateral Investment Treaty

This article discusses an Arbitral Tribunal’s award under a bilateral investment treaty in the Cairn case re

Applying Articles 9 and 24 of the OECD Model to Thin Capitalization Rules

Thin capitalization occurs when an entity is financed using a relatively high amount of debt compared with equ

Participation’s/ Events

The Lisbon International & European Tax Law Series Paper: Substantive Scope or Income Taxes covered by tax

Hyperfocus: How to Be More Productive in a World of Distraction – Book by Chris Bailey

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., [...]

Start with Why: How Great Leaders Inspire Everyone to Take Action – By Simon Sinek

Key takeaways The book’s primary focus is to reflect on the need to start with ‘WHY’ in all endeavou

Bilateral Investment Treaties – India and beyond

In this article, the author examines bilateral investment treaties, noting the rise and decline in theirpopula

Yet not completely lost – Trip Advisor valuation

The report intends to present the valuation undertaken on a travel meta-search platform TripAdvisor Inc. Secti

The future of arm’s length principle – Is there a need to revisit the principle?

Under existing laws and tax treaties of most countries, TP rules are predicated on the ALP. The principlerequi

BEP 2.0: Pillar 2, tax incentives and its interplay – Can subsidies replace tax incentives?

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Applicability of bilateral tax treaties in triangular cases – Part 5

In Part 4, I have discussed Dual resident triangular case. In this part, i am focusing on fourth situation i.e

Applicability of bilateral tax treaties in triangular cases – Part 4

In Part 3, I have discussed Reverse PE triangular case. In this part, i am focusing on third situation i.e. Du

Applicability of bilateral tax treaties in triangular cases – Part 3

In Part 2, I have discussed PE triangular case. In this part, i am focusing on second situation i.e. Reverse P

Applicability of bilateral tax treaties in triangular cases – Part 2

In part 1, I have discussed some of the situations in which triangular cases arise. In this part, i am focusin

Applicability of bilateral tax treaties in triangular cases – Part 1

The aim of this article is to identify possible scenario’s of triangular cases. Often, situation arises in w

Non-discrimination clause in tax treaties – Select issues and recent developments – Part 6

  In part 5 of the series, I have discussed Article 24(4) which deals with deduction non-discrimination i

Non-discrimination clause in tax treaties – Select issues and recent developments – Part 5

In part 4 of the series, I have discussed Article 24(3) which deals with PE non-discrimination in detail. In t

Non-discrimination clause in tax treaties – Select issues and recent developments – Part 4

In part 3 of the series, I have discussed Article 24(2) which deals with stateless person in detail. In this p

Non-discrimination clause in tax treaties – Select issues and recent developments – Part 3

In part 2 of the series, I have discussed Article 24(1) which deals with Nationality non-discrimination in det

Non-discrimination clause in tax treaties – Select issues and recent developments – Part 2

In part 1 of the series, I have given an overview of Article 24 on Non-discrimination. In this part, I will di

Non-discrimination clause in tax treaties – Select issues and recent developments – Part 1

<<The purpose of this series is to have discussion on non-discrimination clause of the bilateral tax tre

Foreign tax credit – Part 6

Various unresolved issues – Issues that are arising in context of Foreign tax credit (‘FTC’) are 

Foreign tax credit – Part 5

Credit method (continued) Tax sparing credit method – Under this, taxpayer will get credit of the amoun

Foreign tax credit – Part 4

Credit method – Country of residence retains the right to tax the foreign income but credit is allowed

Foreign tax credit – Part 3

Bilateral tax credit – Relief provided pursuant to DTAA between the two countries are known as Bilatera

Foreign tax credit – Part 2

Unilateral tax credit – Section 91 of Income Tax Act, 1961 (‘Act’) enables its residents to avail unilat

Foreign tax credit – Part 1

Since, each nation have differenent rules of taxing persons, the same income may get taxed more than once (oft

Controlled foreign corporation rules – Part 3

Select jurisdictions CFC rules CFC legislation is adopted in many countries although with some differences. It

Controlled foreign corporation rules – Part 2

Example Where a resident(s) of Country A is able to influence or control an entity that is resident(s) of Coun

Controlled foreign corporation rules – Part 1

Overview of Controlled Foreign Corporation (CFC) rule – Controlled foreign company (‘CFC’) rul

Is there a need to revisit Arm’s Length Principle?

Introduction Arm’s length principle (‘ALP’) was introduced a century ago to ensure proper allocation of

Whether Article 9(1) is illustrative or restrictive!

Article 9(1) of the MC states the ALP that is applicable to commercial and financial relations betweenassociat

A walk-through into Tesla’s open Patent strategy and the future of patents

I. Tesla’s open patent strategy Tesla’ per se open patent strategy[1] can be attributed to a wide

How A Value Chain Analysis Can Capture The Value Creation Of Data

The modern innovative business models in this era of the digital data economy are giving rise to highly integr

Exploring The Data Ecosystem

I. What is a data ecosystem and why it matters 1. The origin of the term ecosystem Although there might b

What Is Data-defining Data From Different Angles

Just imagine you being in a data conference throwing out the just cited definition. Probably you will rather l

Data economy – Giving rise to new economy

The current era of confluence of data, storage, algorithms, and computational power has set the phase of creat

Understanding Games theory – Part 1

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.