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In this issue

Base Erosion & Profit Shifting : Action Plan 10: Low value adding intra-group services, Action Plan 15: Developing a multilateral instrument to modify Bilateral Tax Treaties, Transfer Pricing : Judicial position on reporting an international transaction in Form 3CEB • Disputes in captive IT/ITeS space • Location saving - Eating savings of outsourcing. Treaty Dispute Resolution : An initiative to establish a Permanent Tribunal for Treaty Arbitration. Industry Analysis : E-commerce: From Brick and Mortar to click and order economy. Arbitration

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