Ultimately, Tiger Global will bring radical accountability to international investment law. The biggest question is whether unilateral source-country anti-abuse measures can be adopted within the existing treaty framework or whether renewed multilateral coordination is necessary.

The 2025 update of the OECD commentary represents an important step towards harmonizing the definition of PE in modern business practices in cross-border remote work and mobile extractive industries.

India now stands at the crossroad of remaking transfer pricing not merely a regulatory stick, but a strategic tipping stone of fair trade, investment confidence and tax equity.

The suspension of the MFN clause in the India-Switzerland DTAA is a significant shift in international tax treaties.

[Karan Shelke is a student at Maharashtra National Law University, Mumbai.] Several years ago, The Economist noted that data generated...