Essays on International Taxation





Fiscally transparent entities and tax treaty eligibility
Shefali Goradia

Triangular cases – the neglected problem in tax treaty law
Michael Lang

Can tax treaty entitlement provisions for hybrid entities be refined?
Dhruv Sanghavi

Non-discrimination provisions in tax treaties
Ajay Vohra

Two to tango: a dance of substance and form
Bijal Ajinkya

Deconstructing Principal Purpose Test under Article 7 of MLI
Mukesh Butani

Preventing treaty abuse in the context of multilateral instrument
Dinesh Kanabar and Saurabh Shah

Taxation of digital economy – the journey, India and across the world
Daksha Baxi

Digitalisation of the economy: Our perspective on the OECD’s Unified Approach
Vikram Chand

Reflections on the 2019 OECD proposal on Pillar One
Guglielmo Maisto

Implementation of BEPS and Amendments to Section 9
Radhakishan Rawal

Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention
Clive M. Baxter

Tax laws through a constitutional prism
Arvind P. Datar

Tax policy as a tool to enable impact investment and improve CSR targeting
Meyyappan Nagappan and Nehal Binani

Tax system design – an analysis of some design choices made by the Indian Income Tax Act, 1961
Shreya Rao

Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty
H. David Rosenbloom

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