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Coverage of the IFA Congress 2014

Coverage of the IFA Congress 2014
15 Oct 2014

First published in Taxsutra, 14 October 2014

Taxand India and Taxsutra bring you an overview of the second day of the IFA Congress in Mumbai and a guide to 'Scaling BEPS'.

Day 2

Day 2 began with the plenary session on “Cross-border Outsourcing – issues, strategies and solutions”. The focus of the subject was to discuss how various jurisdictions are dealing with the concept of outsourcing from a tax perspective and highlight key challenges faced by Multi-National Entities (MNEs).

In the session on indirect transfer taxation, the panel discussed tax policy in different countries on the same as well as the role of anti-abuse law to prevent non-taxation. The panel noted that indirect transfer concept is currently used in treaties mainly in the context of transfers involving immovable property.

Day 3

Day 3 of the IFA Mumbai Congress witnessed discussions on some of the classical tax issues. In the plenary session - “Qualification of Taxable entities and Treaty Protection”, the focus was on  how conflicts of entity qualification affect entitlement to treaty benefits and how these conflicts should be addressed. 

The highlight  of the day was the judges seminar chaired by Senior Advocate Soli Dastur and comprising of judges from USA, France, Canada and India. The elite panel discussed general issues in interpretation of Tax treaties, viz., whether a Treaty would override domestic Income Tax Act if more favourable; the effect of introduction of a subsequent adverse provision in the domestic Act on the Treaty; the concept of “Cherry Picking” between the domestic law and Treaty by a tax-payer in case of different incomes in the same year / same type of income from different countries / year-wise adoption of provisions and the impact of Vienna Convention on interpretation of tax treaties.

Discover more> Access Taxsutra's full coverage of IFA day 2
Discover more > Access Taxsutra's full coverage of IFA day 3
Discover more > Access Taxand India and Taxsutra's guide, 'Scaling BEPS'
Discover more> Access Taxand India's video recap of IFA day 2
Discover more > Access Taxand India's video recap of IFA day 3 and an interview with Jeffrey Owens

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Taxand's Take

The focus of the IFA Congress 2014 is on the key tax challenges faced by multi-national corporations operating across the world. Taxand India in partnership with Taxsutra provide daily recaps of the topics and sessions from the IFA Congress 2014 in Mumbai.

Taxand's Take Author

Mukesh Butani
Taxand Board member