Archive · 19 Aug 2026
India Balances Tax Base Protection With Investor Certainty
India is updating the rules it uses to tax international businesses.
Officials say the country must collect the taxes it is owed.
They also say investors need rules that are stable and predictable.
A Supreme Court decision involving Tiger Global has influenced this discussion.
India has now completed more than 1,000 advance pricing agreements.
More than 220 of those agreements are with other countries.
Artificial intelligence is changing how businesses work and how taxes are administered.
Officials said countries will need to cooperate because technology is developing faster than tax rules.
India’s international tax policy must protect tax revenues while offering stability and predictability to global investors, Monica Bhatia said.
Bhatia said the Supreme Court’s Tiger Global judgment and the new Income-tax Act are reshaping international taxation.
India has concluded more than 1,000 advance pricing agreements, including over 220 bilateral agreements.
Officials said artificial intelligence is creating new questions about permanent establishments, profit attribution and value creation.
The conference discussed BEPS 2.0, treaty changes, safe harbours and cross-border dispute resolution.
- Who
- Monica Bhatia, Rakesh Nangia and Sandeep Chaufla spoke at the conference, alongside other international tax participants.
- What
- The conference examined how India should balance tax-base protection with certainty for international investors while adapting its tax framework.
- When
- The remarks were made on Wednesday at the 23rd International Tax Conference.
- Where
- The conference was held in New Delhi, India.
- Why
- International tax rules are being reshaped by the Tiger Global judgment, new legislation, global minimum tax developments, artificial intelligence and evolving cross-border business models.
Tax-Base Protection
Investor Certainty
Core policy balance
Tax-Base Protection
Governments want to protect their tax bases and ensure that economic activity is taxed appropriately.
Investor Certainty
Global investors and taxpayers want stable, predictable and certain rules.
Policy implementation
Tax-Base Protection
Officials and policymakers are considering new legislation, global minimum tax rules and stronger tax administration to address evolving business models.
Investor Certainty
Tax rules and their implementation should avoid uncertainty for bona fide legacy investments and other compliant taxpayers.
Technology and rule-making
Tax-Base Protection
Artificial intelligence may create new challenges involving permanent establishments, profit attribution and the location of value creation.
Investor Certainty
Because technology is advancing faster than existing rules, international cooperation and consensus-based rule-making are needed for consistent outcomes.
- Conference
- 23rd International Tax Conference organised by ASSOCHAM
- Location
- New Delhi
- Key official
- Monica Bhatia, Principal Chief Commissioner of Income Tax (International Tax)
- Advance pricing agreements
- India has crossed 1,000 agreements
- Bilateral agreements
- More than 220 of India’s advance pricing agreements are bilateral
- Major legal development
- The Supreme Court’s Tiger Global judgment
- Emerging issue
- Artificial intelligence’s effect on permanent establishment, profit attribution and value creation