Recent Blog Articles

Landmark decisions of the Indian and the Portuguese Supreme Courts on whether software income amounts to ‘royalty’ under Art. 12 of tax treaties: Two Paths for the same destination
This article analyzes in-depth a decision of the Indian Supreme Court and a decision of the Portuguese Supreme Court on software income characterization from the tax treaty perspective...Read more

Permanent Establishment (PE): Could a joint-bidding bidding with an Indian company give rise to a foreign company’s PE in India?
 This article analyzes a judicial decision dealing with the issue as to whether joint-bidding by a foreign company with its Indian subsidiary, and whether use of offices of the Indian subsidiary, could give rise to the foreign permanent establishment in India...Read more

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  • Article 5 of Tax Treaties
      (Permanent Establishment)
  • Article 7 of Tax Treaties
      (Business Profits)
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