Much time and attention has been devoted to planning for a post-BEPS world, from analysing systems that may need to be adopted to looking at how taxpayer-tax authority relationships are likely to change. But less has been said about the impact of BEPS deliverables on commercial contract documentation and the extent to which such contracts will be scrutinised. Jen Winterhalder, a solicitor in PwC Legal and Latika Sharma, a partner and head of PwC Legal’s intellectual property and commercial contracts team, focus on the importance of matching contract terms to commercial substance, both now and for the future.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
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