IN the year 2013, the CBDT had introduced the Safe Harbour Rules ('SHR'), optional for a taxpayer, with the conditions and circumstances under which norms / operating margins would be accepted for certain categories of international transactions by the tax authorities. The safe harbour margins are akin to an arm's

THE conference on tax treaty case laws around the globe took place in Vienna this year. As in earlier years, the most important case laws decided in different parts of the world were discussed. It is quite fascinating to observe the differing attitudes of the tax administrations and the tax courts in different parts