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One would arrive at this conclusion after going through documents released at the recently concluded International Monetary Fund (IMF)/World Bank (WB) annual meetings.
The unfortunate aspect of such MIs' THE BEPS project is now almost 4 years old.
Tax treaties usually contain provisions that limit the benefits they accord where excessive interest is paid.
For instance, Article 12(9)of India UK DTAA states that the restriction by way of any provision in laws of either contracting state on interest payment to non-resident company shall not operate(not applicable in holding subsidiary relationship).
The provisions are not applicable in case where interest expenses are less than or equal to Rs.