A comprehensive exploration of Double Taxation Avoidance Agreements, encompassing prevailing issues & practices as well as emerging trends. The book analyses Pillar 1 & 2, pertinent issues within select industries, new tax architecture trends & the relevance of OECD amid challenges posed by developing countries. The rationale of the book is to detail the concepts including Interpretation of Treaties and Approach, Analysis of the provisions, challenges and practices on various issues of Permanent Establishments (PE), Attribution of Profits, Capital Gains and Indirect Transfer, Royalty and Fees for Technical Services, Dependent and Independent Personal Services, Most Favoured Nation Clause, Foreign Tax Credits and Anti Avoidance Regulations. Emerging Trends on New Age Industries and Technology are discussed in the book. Also the concept of Pillar 1 & Pillar 2 as well the Economic Impact on Pillar 1 & Pillar 2 for Developing Countries including India is analysed. The book has been concluded with the need for new Global Tax Architecture and the role of India in the emerging scenarios. It is a useful reference for tax professionals, policy-makers, enforcement authorities, academicians & tax students.
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