1. Illustrations of “Thinking inside the Box”
Page No. 18
IV. Equalisation Levy
Illustrations of
“Thinking inside the Box”
CA. Rashmin Sanghvi

2. Page No. 19
Traffic Rules

3. Conventional Horse Carriage
Page No. 20
Conventional Horse Carriage

4. Initial Design of a Motor Car- Remix of a Horse Carriage
Page No. 21
Initial Design of a Motor Car- Remix of a Horse Carriage
Motorised Car manufacturers replaced the horse by a motor-engine. Everything else was kept similar to a horse carriage. They could not think “Out of Box”. Initially several car manufacturers went insolvent.

5. Page No. 22
Modern Driverless Car
Once the “In Box Thinking” was scrapped, car designs have changed significantly.

6. Page No. 23
An Aircraft
With advancing technology, means of transport have changed significantly.

7. Page No. 24
From Horse Cart to Car, Car to Plane All are vehicles, but the RULES of traffic management are different.

8. Aircraft Control Tower
Page No. 25
Aircraft Control Tower
The signal systems for cars & aircrafts are different. Traffic Rules are completely different.

9. Page No. 26
Can the Pilot ask:

10. Outcome of applying road traffic rules to aircrafts
Page No. 27
Outcome of applying road traffic rules to aircrafts
If E-Commerce taxation stays within OECD parameters – this will happen. PE & old rules of international taxation are like – Road Traffic Rules. E-Commerce taxation rules should be like Air-craft Traffic Control (ATC).

11. Road Traffic Rules are valid for cars etc. & invalid for aircraft.
Page No. 28
Road Traffic Rules are valid for cars etc. & invalid for aircraft.
Rules must change as technologies change.

12. Boxes within Legal Field
Page No. 29
Boxes within Legal Field
Accepted International Traditions. International Law.
Constitution of India
Palkhivala.
He was great. But in tax law. Did not travel outside India.
OECD Colonisation
ITA. As passed.
Interprete the written words
99%
Box 1 – 99% of the tax professionals & administrators interprete law, the written words. Box 2 – Rare persons look at a macro level – the Constitution, Jurisprudence etc. Even late Mr. Palkhivala did not look at International Taxation. Box 3 – International Taxation – bound by OECD & UN Models, etc.

13. Come up & above OECD & UN Models
Page No. 30
Come up & above OECD & UN Models
Come out of ALL the 3 Boxes.
Consider what is “Fair &
Just” for all.

14. There are people who won’t come out of the Boxes.
Page No. 31
There are people who won’t come out of the Boxes.
And there are people ready to come out of all boxes.
The 1st category will criticise the 2nd.

15. Page No. 32
David Vs. Goliath

16. Disruptive Technologies David Vs. Goliath is an old story.
Page No. 33
Disruptive Technologies
Avalanche of changes.
David Vs. Goliath is an old story.
Today there are 15 Davids.
There are more than 15 nations preparing their own tax laws for taxing NR E-Commerce Service Provider.