Concept of "Safe Harbour Rules" under Income Tax Act 1961

Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions, thus "eroding" the "tax-base" of the higher-tax jurisdictions.

source https://www.caclubindia.com/articles/safe-harbour-rules-under-income-tax-act-1961-47010.asp