Beneficial ownership: how much commercial substance does treaty relief really need in 2026?
Beneficial ownership is no longer a box-ticking treaty concept. In 2026, Indian treaty relief turns on whether the recipient truly controls, retains, and bears the income.
Remote Work Permanent Establishment Risk: Has Practice Caught Up With Post-Pandemic Delivery?
Remote work permanent establishment risk now turns on people functions, home-office facts, agent behaviour and treaty thresholds - not just branches, leases or frequent travel
Equalisation levy: is it living on borrowed time in a Pillar One–Pillar Two world?
Equalisation levy may be off the statute book prospectively, but its repeal says as much about OECD pressure and compliance friction as it does about digital tax reform.
Faceless penalty after assessment: why natural justice is becoming the decisive defence
Faceless penalty disputes in India are increasingly turning on procedural fairness. As digital assessments mature, natural justice is emerging as the most serious defence in penalty litigation.
GAAR in India after a decade: credible deterrent or underused headline provision?
A decade after GAAR entered the statute book, India’s anti-avoidance rule looks less like a daily weapon and more like a quiet constraint on how aggressive planning gets priced.