Akshay Jahagirdar

Associate

Biography

“As simple as possible, but not one bit simpler” (Albert Einstein). That is Akshay’s motto. He is analytically strong, loves to sink his teeth into a subject and get to the bottom of it. With his passion for the profession and excellent communication skills, he provides sound advice.

  • Has been working at NovioTax since April 2025.
  • He focuses on transfer pricing advice and international tax law.
  • Is pursuing a PhD in international tax law at Maastricht University.
  • Gained work experience at an international tax consultancy firm in The Hague.
  • After emigrating to the Netherlands, he completed the Advanced LLM in International Taxation at the University of Amsterdam.
  • Gained work experience in India at KPMG and several boutique firms.
  • Studied to become a Chartered Accountant in India.
  • Speaks and writes: English, Hindi, Marathi and Kannada.

Blogs written by Akshay

Implicit substance threshold embedded within the PE concept? Lessons from Luxembourg – Part III

Authors: Patrick Schrievers, Akshay Jahagirdar
This blog is Part 3 of a 3-part series analysing two Luxembourg cases related to (implicit) substance threshold for recognizing non-trading foreign branch offices as permanent establishments for availing exemptions from Luxembourg’s annual net wealth tax. This blog comprises our observations and key takeaways from the two cases discussed in Part 1 & 2.

Implicit substance threshold embedded within the PE concept? Lessons from Luxembourg – Part II

Authors: Patrick Schrievers, Akshay Jahagirdar, Roya Rezaiee
This blog is Part 2 of a 3-part series analyzing two Luxembourg cases related to (implicit) substance threshold for recognizing non-trading foreign branch offices as permanent establishments for availing exemptions from Luxembourg’s annual net wealth tax. This blog outlines Case #2, concerning the recognition of a PE in the U.S., along with general observations and comments on the burden of proof.

Implicit substance threshold embedded within the PE concept? Lessons from Luxembourg – Part I

Authors: Patrick Schrievers, Akshay Jahagirdar
This blog is Part 1 of a 3-part series analysing two Luxembourg cases related to (implicit) substance threshold for recognizing non-trading foreign branch offices as permanent establishments for availing exemptions from Luxembourg’s annual net wealth tax. This blog outlines Case #1, concerning the recognition of a PE in Malaysia, along with general observations and comments on the burden of proof.

Colombian TP-case highlights PLI-selection and proper substantiation of comparability adjustments

Authors: Akshay Jahagirdar
The key dispute in the case arose from (i) a difference in accounting treatment (Colombian GAAP vs. IFRS/US GAAP) of reimbursements from a related party; (ii) selection of appropriate PLI. Relying on expert opinion , the court concluded that the comparability adjustments proposed by the taxpayer were reasonable and justified to achieve better comparability between the taxpayer and the comparable companies. By accepting the comparability adjustment, the court implicitly recognized that accounting classification (expense vs. capitalized; COGS vs. OPEX) can materially swing outcomes under an OPEX-based PLI (e.g., ROTC) and an asset-based PLI (e.g., ROCE).

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