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TMI BlogAction Plan 1 – Challenges of Taxation in Digital EconomyX X X X Extracts X X X X X X X X Extracts X X X X ..... a and characterisation , and that relate to the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among countries. While some options to address these concerns were discussed, no consensus emerged and decision was made to continue working in this area. This continued work led to the delivery of an Interim Report in March 2018 anal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e current international tax architecture, as they entail modifications potentially going beyond the arm s length principle and no longer constrained by physical presence requirements. OECD Recommendations under Action Plan 1 of the BEPS project. Modifying the existing Permanent establishment (PE) rule to provide whether an enterprise engaged in fully de-materialized digital activities w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ined the Two-Pillar Solution to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate. Pillar One Re-allocation of taxing rights Pillar One will ensure a fairer distribution of profits and taxing rights among countries with respect to the largest MNEs, including digital companies. It would re-allocate some taxing right ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... international tax system and the increased tax certainty for taxpayers and tax administrations. See Global Anti-Base Erosion Model Rules published on 20 December 2021, which delineate the scope and set out the operative provisions and definitions of the GloBE Rules. These rules are intended to be implemented as part of a common approach and to be brought into domestic legislation as from 2022. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome Tax Act, 41961 read with the DTAA notified by the CG under section 90 or section 90A. Further, the concept of Significant Economic Presence (SEP) which is similar to the virtual fixed place PE as recommended in the 2015 BEPS Action Plan 1 report is being introduced vide Explanation 2A to section 9(1)(i), effective from AY 2022-23. - Manuals - Ready reckoner - Law and practice - Refer ..... X X X X Extracts X X X X X X X X Extracts X X X X
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