New Delhi, August 19, 2026: India’s international tax framework is at a critical juncture, with the country needing to balance protection of its legitimate tax base with policy stability, predictability and certainty for global investors, Ms. Monica Bhatia, Principal Chief Commissioner of Income Tax (International Tax), New Delhi, Ministry of Finance, said today.
Addressing the 23rd International Tax Conference organised by the Associated Chambers of Commerce and Industry of India (ASSOCHAM) in New Delhi, Ms. Bhatia said the Tiger Global judgment, the new Income–tax Act, evolving dispute-resolution mechanisms and rapid advances in technology were reshaping the international tax landscape. She emphasised that substance, commercial rationale, policy stability and greater certainty would remain important to investor confidence.
“Policy stability is foundational to investor confidence,” she said, highlighting the government’s measures following the Tiger Global judgment to provide greater certainty to bona fide legacy investments. She also highlighted India’s progress on Advance Pricing Agreements (APAs), with the country crossing 1,000 agreements, including more than 220 bilateral agreements, and said stronger cooperation between taxpayers, professionals and the tax administration would be key to reducing tax disputes.
Looking ahead, she said AI was changing business models and tax administration, raising new questions around permanent establishment, profit attribution and the location of value creation. She stressed that international cooperation and consensus-based global rule-making would become increasingly important as technology evolves faster than existing tax rules.
Earlier, Mr. Rakesh Nangia, Chairman, Task Force on International Taxes, ASSOCHAM and Founder & Managing Partner, Nangia & Co LLP, said international taxation had moved from a phase of rapid evolution to a period of fundamental transition, with the Tiger Global judgment, new tax legislation, global minimum tax developments and AI shaping the next phase. “Last year, we spoke about a tax landscape in rapid evolution. Twelve months on, this evolution has become a transition,” he said, highlighting the need for India’s tax framework to keep pace with emerging global developments.
Mr. Sandeep Chaufla, Chairman, National Council on Direct Taxes, ASSOCHAM, said the changing international tax environment required a balance between protecting the tax base and providing certainty and predictability to taxpayers. “Governments across the world are seeking to protect their tax base and taxpayers are seeking certainty and predictability. Therefore, balance in terms of legislation and its implementation is the need of the hour,” he said, while highlighting the growing role of AI in tax administration. “This is an opportunity for us to mingle actual intelligence with artificial intelligence,” he added.
The conference featured four sessions covering the post-Tiger Global tax landscape, AI and international tax policy, BEPS 2.0, treaty evolution, the new Income–tax Act, APAs, safe harbours and cross-border dispute resolution, with discussions focused on strengthening certainty and predictability while ensuring India’s tax framework keeps pace with changing business models, technology and global tax reforms.
Delivering the vote of thanks, Mr. Atul Puri, Co-Chair, Task Force on International Taxes, ASSOCHAM, highlighted the importance of continued engagement between taxpayers, industry and Revenue authorities in addressing emerging international tax challenges.