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Mystiques of MLI Brought Alive Book

Mystiques Of MLI Brought Alive

by H. Padamchand Khincha, K. K. Chythanya
MLI
Categories: International Taxation
Publisher: Taxsutra and Thomson Reuters South Asia Private Limited
About Book:

MLI was conceptualized to prevent BEPS. The reach of MLI is far, deep and intricate. The subject is complex. The challenges lie in comprehending the semantics for which guidance is cryptic. The subject apparently struggles between prescription and precision. While the intent of MLI is to deter treaty abuse, the form appears to disturb even a permissible arrangement. The anti-abuse measures have ushered in roadblocks which a taxpayer would have to labour really hard to surmount. One wonders if it is worth so much investment of time, effort and administration to defend taxes of around 0.5% of global GDP. Exchequers across the globe have been steadfast in evolving ‘unilateral’ and ‘disparate’ solutions. This leads to unity in problem identification and diversity in execution of tax measures. India has been the front runner in importing these anti-abuse measures. MLI is a reality today. It cannot be ignored by the tax-paying community or advisors. A concerted effort is needed to demystify MLI. Mystiques of MLI Brought Alive travels through certain less-spoken provisions of MLI, their interplay with domestic tax laws and bilateral treaty provisions. The objective is to delve into the mystiques of MLI.

Authors: H. Padamchand Khincha, K. K. Chythanya
About Authors:
H. Padamchand Khincha :

H. Padamchand Khincha is a partner in H C Khincha & Co and H C Khincha & Associates, Bangalore. With over 30 years of experience in corporate and international tax regime, he has spearheaded the income- tax consultancy and litigation practice. He advises multinational companies, Indian companies as well as high networth individuals on various tax matters including tax structuring, due diligence, transfer pricing and compliance aspects. He has represented large corporates in some of the high- profile cases before various Income- tax tribunals across India and has been associated with several landmark decisions too.

Padamchand Khincha is a prolific writer on various topics in income- tax. He has authored the book ‘Emerging Issues in International Taxation’. He has co- authored “Permanent Establishment – Emerging trends”, “Decoding section 5”, “Tax Holiday U/s.10A and 10B - An analysis”; “Tax Treaties of India - A compilation”; “Capital gains of Non- residents”; “Tax deduction at source”; “Concept of Indexation under capital gains”.

He has contributed to various articles and papers published by The Chamber of Tax Consultants, ITRAF, BCAS. He has authored and co- authored articles across various tax magazines including the Taxmann publication, Bombay Chartered Accountants Journal, ITR etc. He has delivered more than 500 lectures across the nation on several income- tax issues.

He has been actively engaged in several initiatives undertaken by the Institute of Chartered Accountants of India (ICAI). He was appointed the group leader for preparing the approach paper on the Guidance Note on Transfer Pricing. He was instrumental in making a critical analysis of the Direct Tax code as a member of the team constituted by ICAI on the request on CBDT. He was a member of Committee of ICAI involved in preparing the technical background paper on Income Computation and Disclosure Standards. He deposed as an expert before (a) high powered committee on E. commerce constituted by the Central Board of Direct Taxes in India; (b) Rangachary Committee set up to “Review Taxation of Development Centres and the IT Sector; and (c) by the A P Shah Committee constituted by the Government of India to examine the matters relating to MAT on FII/ FPI(s). He was a country reporter for India for IFA Rio de Janeiro Congress 2017 on ‘Assessing BEPS - Origin, Standards, Responses’. He is on the editorial board constituted for International Tax Journal published by the Chamber of Tax Consultants.

His teaching stints in the past include guest lectures at IIM, Bangalore; intensive coaching classes of ICAI; faculty at the Direct Taxes Training Institute of the Income Tax Department. Padamchand Khincha is a Commerce graduate from the University of Bangalore securing 5th Rank at the University level. He holds a Bachelor’s degree in Law.
He qualified as a Chartered Accountant in 1982 by securing the 25th rank.

K. K. Chythanya :

K.K. Chythanya has over 31 years of experience in taxation matters and is an advocate practicing in the Karnataka High Court. He holds briefs in the Supreme Court as well as in other High Courts.

He has authored a book on Special Economic Zone and co- authored two books viz, “Tax Holiday under Section 10A and 10B – An analysis” and “Decoding Section 5 – Analysis of scope of total income under Income Tax Act, 1961”. He has contributed several articles to ITR, Chartered Accountant, Bombay Chartered Accountants Journal, Taxmann, Current Tax Reporter and other journals. He has also presented paper on Income Tax and GST/ VAT at various forums including ICAI, BCAS, CTC – Mumbai, IFA, Society of Auditors, AIFTP and BCIC.

He has addressed at IIM, Bengaluru; MDP of ICAI, New Delhi; MDP of ICAI, Bengaluru and Direct taxes training centre of Income tax department. As a member of study group of ICAI, he has been instrumental in framing the Guidance Note on Transfer Pricing.

He has deposed before Committee on Direct Tax Matters headed by Hon’ble Justice A P Shah on the levy of MAT on FIIs and has been a country reporter for India for IFA Seoul Congress 2018 on ‘withholding tax’. A meritorious student throughout his academic life, Sri. K.K. Chythanya is a Commerce graduate from Mysore University securing 1st Rank and a qualified Chartered Accountant with 1st position in Karnataka and an impressive 15th position across India.

About Publisher:

About Taxsutra:

Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.

Taxsutra suite of portals : 

1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law 
6.  Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)

About Thomson Reuters South Asia Private Limited:

Thomson Reuters is one of the world’s most trusted providers of answers, helping professionals make confident decisions and run better businesses. Thomson Reuters, India, Legal is a part of this group and publishes legal content covering a spectrum of topics by leading experts and professionals in this domain. Newgen, a contracting affiliate of Thomson Reuters, India, Legal produces and promotes these publications on their behalf across South East Asia. 

Similar Books

Ratings and Reviews

Overall Rating
Review
MLI
Categories: International Taxation
Publisher: Taxsutra and Thomson Reuters South Asia Private Limited
About Book:

MLI was conceptualized to prevent BEPS. The reach of MLI is far, deep and intricate. The subject is complex. The challenges lie in comprehending the semantics for which guidance is cryptic. The subject apparently struggles between prescription and precision. While the intent of MLI is to deter treaty abuse, the form appears to disturb even a permissible arrangement. The anti-abuse measures have ushered in roadblocks which a taxpayer would have to labour really hard to surmount. One wonders if it is worth so much investment of time, effort and administration to defend taxes of around 0.5% of global GDP. Exchequers across the globe have been steadfast in evolving ‘unilateral’ and ‘disparate’ solutions. This leads to unity in problem identification and diversity in execution of tax measures. India has been the front runner in importing these anti-abuse measures. MLI is a reality today. It cannot be ignored by the tax-paying community or advisors. A concerted effort is needed to demystify MLI. Mystiques of MLI Brought Alive travels through certain less-spoken provisions of MLI, their interplay with domestic tax laws and bilateral treaty provisions. The objective is to delve into the mystiques of MLI.

Authors: H. Padamchand Khincha, K. K. Chythanya
About Authors:
H. Padamchand Khincha :

H. Padamchand Khincha is a partner in H C Khincha & Co and H C Khincha & Associates, Bangalore. With over 30 years of experience in corporate and international tax regime, he has spearheaded the income- tax consultancy and litigation practice. He advises multinational companies, Indian companies as well as high networth individuals on various tax matters including tax structuring, due diligence, transfer pricing and compliance aspects. He has represented large corporates in some of the high- profile cases before various Income- tax tribunals across India and has been associated with several landmark decisions too.

Padamchand Khincha is a prolific writer on various topics in income- tax. He has authored the book ‘Emerging Issues in International Taxation’. He has co- authored “Permanent Establishment – Emerging trends”, “Decoding section 5”, “Tax Holiday U/s.10A and 10B - An analysis”; “Tax Treaties of India - A compilation”; “Capital gains of Non- residents”; “Tax deduction at source”; “Concept of Indexation under capital gains”.

He has contributed to various articles and papers published by The Chamber of Tax Consultants, ITRAF, BCAS. He has authored and co- authored articles across various tax magazines including the Taxmann publication, Bombay Chartered Accountants Journal, ITR etc. He has delivered more than 500 lectures across the nation on several income- tax issues.

He has been actively engaged in several initiatives undertaken by the Institute of Chartered Accountants of India (ICAI). He was appointed the group leader for preparing the approach paper on the Guidance Note on Transfer Pricing. He was instrumental in making a critical analysis of the Direct Tax code as a member of the team constituted by ICAI on the request on CBDT. He was a member of Committee of ICAI involved in preparing the technical background paper on Income Computation and Disclosure Standards. He deposed as an expert before (a) high powered committee on E. commerce constituted by the Central Board of Direct Taxes in India; (b) Rangachary Committee set up to “Review Taxation of Development Centres and the IT Sector; and (c) by the A P Shah Committee constituted by the Government of India to examine the matters relating to MAT on FII/ FPI(s). He was a country reporter for India for IFA Rio de Janeiro Congress 2017 on ‘Assessing BEPS - Origin, Standards, Responses’. He is on the editorial board constituted for International Tax Journal published by the Chamber of Tax Consultants.

His teaching stints in the past include guest lectures at IIM, Bangalore; intensive coaching classes of ICAI; faculty at the Direct Taxes Training Institute of the Income Tax Department. Padamchand Khincha is a Commerce graduate from the University of Bangalore securing 5th Rank at the University level. He holds a Bachelor’s degree in Law.
He qualified as a Chartered Accountant in 1982 by securing the 25th rank.

K. K. Chythanya :

K.K. Chythanya has over 31 years of experience in taxation matters and is an advocate practicing in the Karnataka High Court. He holds briefs in the Supreme Court as well as in other High Courts.

He has authored a book on Special Economic Zone and co- authored two books viz, “Tax Holiday under Section 10A and 10B – An analysis” and “Decoding Section 5 – Analysis of scope of total income under Income Tax Act, 1961”. He has contributed several articles to ITR, Chartered Accountant, Bombay Chartered Accountants Journal, Taxmann, Current Tax Reporter and other journals. He has also presented paper on Income Tax and GST/ VAT at various forums including ICAI, BCAS, CTC – Mumbai, IFA, Society of Auditors, AIFTP and BCIC.

He has addressed at IIM, Bengaluru; MDP of ICAI, New Delhi; MDP of ICAI, Bengaluru and Direct taxes training centre of Income tax department. As a member of study group of ICAI, he has been instrumental in framing the Guidance Note on Transfer Pricing.

He has deposed before Committee on Direct Tax Matters headed by Hon’ble Justice A P Shah on the levy of MAT on FIIs and has been a country reporter for India for IFA Seoul Congress 2018 on ‘withholding tax’. A meritorious student throughout his academic life, Sri. K.K. Chythanya is a Commerce graduate from Mysore University securing 1st Rank and a qualified Chartered Accountant with 1st position in Karnataka and an impressive 15th position across India.

About Publisher:

About Taxsutra:

Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.

Taxsutra suite of portals : 

1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law 
6.  Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)

About Thomson Reuters South Asia Private Limited:

Thomson Reuters is one of the world’s most trusted providers of answers, helping professionals make confident decisions and run better businesses. Thomson Reuters, India, Legal is a part of this group and publishes legal content covering a spectrum of topics by leading experts and professionals in this domain. Newgen, a contracting affiliate of Thomson Reuters, India, Legal produces and promotes these publications on their behalf across South East Asia. 

Similar Books

Ratings and Reviews

Overall Rating
Review
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