Improving Taxation Environment: Attracting Foreign Direct Investment

This paper broadly deals with the concerns of the multinationals in the area of taxation environment. Section two of this paper deals with the genesis of the recent crisis in this area and issues involved such as introduction of GAAR, international taxation, retrospective amendment dispute resolution etc. Section three deals with GAAR. Section four deals with various issues involved in the area of international taxation including Permanent Establishment, attribution of profits, transfer pricing, taxation of Information Technology (IT) and Information Technology enabled Services (ITeS)sectors, Advance Pricing Agreements (APAs) and Safe Harbour Rules. [Working Paper 325]