With increase in globalization, geographical boundaries of countries have become blurred and many multinational groups try to get benefit of their global presence to minimize their overall tax costs by using low tax jurisdictions for tax planning.  One of such measures used by multinational groups is to park profits in no/ low tax countries without actually bringing such profits to ultimate parent company located in relatively higher tax jurisdiction.  This practice sometimes results in substantial/ perpetual deferral of tax payments on such profits. Rakesh Nangia, Managing Partner with inputs from Shailesh Kumar, Director, Nangia & Co contributed an article on Budget 2017: Whether India needs a Controlled Foreign Corporation regime for Business Today magazine. Attached is link to the article http://www.businesstoday.in/opinion/columns/whether-india-needs-a-controlled-foreign-corporation-regime/story/245025.html