Mystiques of MLI brought Alive

Author: H Padamchand Khincha and K K Chythanya
Year: 2021

MLI was conceptualized to prevent BEPS. The reach of MLI is far, deep and intricate. The is complex. The challenges lie in comprehending the semantics for which guidance is cryptic.  The subject apparently struggles between prescription and precision. While the intent of MLI is to deter treaty abuse, the form appears to disturb even a permissible arrangement. The anti-abuse measures have ushered in roadblocks which a taxpayer would have to labour really hard to surmount. One wonders if it worth so much investment of time, effort and administration to defend taxes of around 0.5% of Global GDP. A concreted effort is needed to demystify MLI. This book travels through certain less-spoken provisions of MLI, their interplay with domestic tax laws and bilateral treaty provisions. The Objective is to delve into the mystique of MLI