SHADES OF SUBSTANCE, A Treatise on Tax Anti- Avoidance Measures
ABOUT THE BOOK
This book provides an overview of GAAR and the interpretation of its various elements.
In addition to Indian jurisprudence, the book discusses precedents from various other countries including Canada, Australia, New Zealand, UK and South Africa. The principles emerging from these cases and their relevance in an Indian context post the introduction of GAAR have been analysed.
The book also covers several other anti-abuse measures such as POEM, the BEPS Reports and the Multilateral Convention, which are essentially ‘substance’ based. The impact of ‘substance’ on commonly undertaken transactions, such as group restructuring, transfers of assets, sale and lease back etc. are also discussed.
KEY FEATURES OF THE BOOK
Overview of GAAR, interpretation of its various elements and procedural aspects.
- Key anti‐avoidance principles and applicability under GAAR.
- Interplay between GAAR and judicial Anti‐Avoidance rule.
- International precedents on GAAR with relevance in Indian context.
- Overview of BEPS Action Plan 6 and 7, execution of MLI and its impact.
- Concept of POEM, POEM guidelines and judicial precedents.
About the Author:
Rishi Kapadia is a Fellow Member of “Institute of Chartered Accountants of India” and he is a Partner at Dhruva Advisors LLP based in Mumbai.
Rishi has more than 14 years’ experience in the field of Taxation. He has significant experience in advising MNCs and domestic companies on various aspects of domestic and cross border taxation, inbound investment, restructuring etc. across various sectors such as Oil & Gas, Infrastructure, IT/ ITES and FMCG.