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| Format: | Recurso digital |
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Zenodo
2026
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| Online Access: | https://doi.org/10.5281/zenodo.20242008 |
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Table of Contents:
- The rapid growth of the digital economy has laid bare the limitations of an international tax framework built for an earlier age, one defined by physical offices, tangible goods, and fixed territorial presence. India, keenly aware of its scale as a digital market, chose not to wait. Through the Equalisation Levy of 2016 and its significantly broader expansion in 2020, it staked an early claim to tax revenues that traditional rules would have left untouched. At the same time, the OECD, through its BEPS project, was working toward a multilateral answer, the Two-Pillar Solution. This paper examines how India's Equalisation Levy was designed, how it evolved, and what frictions it created, with treaty partners, trading nations, and its own domestic tax architecture. It also traces India's cautious movement toward the OECD's Global Minimum Tax under Pillar Two. The central argument is that India's unilateral approach, whatever its limitations, was a defensible assertion of fiscal sovereignty, but that its longerterm interests are best served by a coordinated global framework, so long as that framework gives adequate weight to the contribution of market jurisdictions like India.