Reimagining International Taxation

Navigating through the crises of pandemic, lack of consensus and retrospective taxation 
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Description
This is the fifth edited volume on prevailing issues in international taxation that ITRAF has produced in its five years of existence. Each volume has emphasized particular areas, for example, a range of existing and continuing challenges in international taxation in the first volume, international tax base erosion through multinational profit shifting (BEPS) in the second volume, an array of issues from the taxation of charitable entities to cryptocurrency as well as taxpayer's rights in the third volume, and international taxation in the digital era, control instruments against tax avoidance, including GAAR and POEM, legislative over-activism and tax treaties in the fourth volume. The present, fifth volume presents a collection of papers in the form of the main a chapters accompanied by rejoinders. To begin, it imparts a sense of crisis and the need for an urgent reform in India's tax structure (Shome with a rejoinder by Butani). This is of particular relevance in the prevailing economic environment and fiscal deficit situation exacerbated by the ramifications of the yet uncontrolled COVID-19 pandemic. The volume then presents prevailing challenges in international taxation, including follies in setting up locations for the international taxation portfolio in international organizations (Baker, with a rejoinder by Shome), the history of how those biases gathered force over the past century (Baistrocchi, with a rejoinder by Shome), nagging issues in the taxation of the digital economy (Sekar and Prasanna Kumar, with a rejoinder by Roy, and Gajaria et al., with a rejoinder by Shome) and, relatedly, to the attribution of profits (Ahuja and Gupta with a rejoinder by Srinivasan) and the source versus nexus controversy (Khincha et al. with a rejoinder by Sekar). In an environment of what may be perceived as excessive taxpayer exposure, the final chapter takes up the issue of a taxpayer's charter (Girish, with a rejoinder by Chaudhary).
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Contents
Chapter 1  :  India in a Global Pandemic-Macro-Economic and Tax Considerations
A SENSE OF CRISIS GLOBAL POWER SHIFTS, TAX ARCHITECTURE, AND RETROSPECTIVITY
Chapter 2  :  The International Tax Regime and Global Power Shifts
Chapter 3  :  The Need for a New International Tax Architecture
Chapter 4  :  Retrospective Taxation and the Vodafone Case
Chapter 5  :  The Vodafone Case-A Plea for Tax Treaty Arbitration
IN SEARCH OF INTERNATIONAL CONSENSUS
Chapter 6  :  Profit Attribution Approaches and Conflicts
Chapter 7  :  OECD'S Pillar One and Pillar Two-An Overview
Chapter 8  :  Source and Nexus of Income
Chapter 9  :  Cryptocurrencies-Income Tax Implications
ADMINISTRATIVE INNOVATION
Chapter 10  :  Taxpayers' Charter
Subject Index
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Author Details
Dr Parthasarathi Shome is Chairman, ITRAF, Bengaluru, and Senior Visiting Fellow, London School of Economics. Earlier, he was Adviser (Minister of State) to the Indian Finance Minister, and chaired the Tax Administration Reform Commission (TARC). Before that, he was Chief Economist, UK Revenue and Customs; Chief of Tax Policy IMF; and Professor, American American University, Washington DC. He chaired India's Ninth and Tenth Five Year Plan Task Forces on tax policy and administration. He received Brazil's highest civilian honour, Commander of the Order of the Southern Cross, for his contributions to Brazilian fiscal reform, and the Jeanne S. Mattersdorf Award of the National Tax Association of America as “an outstanding student in the field of taxation and public finance” for his Ph.D. thesis on the incidence of the corporation income tax. He is widely published and is invited to speak across the globe.