India Clarifies Position on the Acceptance of MAP and Bilateral APA under Tax Treaties without Corresponding Adjustment Provisions

India's Central Board of Direct Taxes (CBDT) has issued a release providing clarification of India’s position on the acceptance of MAP and bilateral APAs in cases where paragraph 2 of Article 9 of the OECD Model (or equivalent) is absent from a relevant tax treaty. Paragraph 2 relates to corresponding adjustments. The release notes that the CBDT has examined the matter and decided that transfe…
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