In the past decade, India has emerged as a key voice in the international tax debate, spearheading developing countries’ source and market based taxation rights (examples include India’s source rules for taxation of indirect transfers and expansion of withholding taxes to fee for technical services under India’s tax treaty network). Through its participation in the G20 and OECD’s BEPS initiative, India has committed to a multilateral approach for securing a fairer, stable and non-discriminatory international tax policy regime for developing nations. It was only natural that India recently backed OECD’s Inclusive Framework, which (amongst other things) aims to address tax