The OECD has published a Model Competent Authority Agreement to facilitate the implementation of its political commitment on Amount B of Pillar One.

Tax jurisdictions can use the Model to implement the political commitment where there is a tax treaty in place. Entering into an Agreement is optional for tax jurisdictions. The absence of such an agreement does not, in itself, impede the implementation of the political commitment, which could be implemented by tax jurisdictions through other means in light of their legal and administrative systems.
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Inclusive Framework members that wish to extend the political commitment to tax jurisdictions not included in the list of covered tax jurisdictions may also use the Model.

South African Revenue Service has issued a general guide providing a high-level overview of the most significant tax legislation administered in the country.

Among other things, the guide relates to companies for the 2024 year of assessment with financial years ending during the 12- month period ending on 31 March 2024.
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For income tax purposes, the guide has been updated to include the Tax Administration Laws Amendment Act 18 of 2023, the Taxation Laws Amendment Act 17 of 2023, and the Rates and Monetary Amounts and Amendment of Revenue Laws Act 19 of 2023.

India’s Bombay High Court today dismissed a writ petition filed by Hindustan Unilever Limited concerning non-deduction of income tax on payment of INR 30.45 billion made to GlaxoSmithKline Consumer Healthcare towards acquisition of certain brands.

The leading FMCG maker had earlier disclosed that it received an INR 9.7 billion tax notice from the Income Tax Department in relation to the said acquisition.

As per the Income Tax Department, the sum remitted by Hindustan Unilever Limited was subject to deduction of tax under section 195 of the Income Tax Act. Because there was a failure to deduct the tax, proceedings under section 201 of the Income Tax Act were initiated treating Hindustan Unilever Limited as “assessee-in-default”.

The company contended before the Bombay High Court that the Department had failed to apply the principle laid down by the Delhi High Court in an earlier decision. In that decision, the Delhi High Court had ruled that the situs of a trademark shall be the situs of the owner.

The company contended that the owner of the brands in the instant case was not situated in India and therefore no sum is chargeable to tax in India under section 9 of the Income Tax Act.
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The Bombay High Court, in a decision pronounced today, declined to entertain the petition in exercise of its extraordinary writ jurisdiction. The court said that Hindustan Unilever Limited has an alternate remedy by way of appeal and must pursue that remedy.