Treaty Shopping

With increased presence of companies across borders and inter-company transactions, treaty shopping has become a controversial issue around the globe and with the increased focus of tax authorities (including regional tax authorities) to plug the treaty shopping rules, it is imperative that business and multinational companies who places heavy reliance on double tax treaties (DTAA) in their international tax strategies, should be aware of the various provisions including GAAR, which may have a negative effect to them.
Our Tax Advisory team is focussed and responds to the above said challenges and guide to businesses on various forms of anti- treaty shopping, which ranges from the application of treaty based provisions to the use of domestic law anti avoidance rules and the substance over form (i.e. purpose, alignment of form and substance, commercial and / or economic value additions etc.) and explore strategies to mitigate the impact of tax exposures of cross border transaction by ethical and legitimate planning and how to maximise the tax treaty benefits and operate in a most tax efficient manner.