BEPS and India - Tax Positions

Until a human being changes internally, morals are imposed upon him externally so that it leads to a gradual realization. Similarly, until all the countries/ stakeholders appreciate the long term evil effects of tax evasion, provisions like Base Erosion and Profit Shifting are introduced.

As a follow up to the OECD Base Erosion and Profit Shifting Project ("BEPS") action plans, the Organisation for Economic Co-operation and Development ("OECD") has proposed changes in the Model Tax Convention or the OECD Model Tax Convention ("MTC"). 

Article 5 of the MTC provides for the concept of Permanent Establishment("PE"). In this article, we are discussing the changes proposed in Article 5 of the MTC pursuant to the BEPS Action plan 7i.e. preventing the artificial avoidance of Permanent Establishment status.