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Technical Discussion: If recipient of dividends is not the beneficial owner, can the tax treaty between the source state and the beneficial owner’s residence state apply?
In a case where Company S in Country S pays dividends to Company R in Country R but the beneficial owner of that income (Company B) is tax resident of Country B, would it be possible to apply the concessional withholding tax rate stipulated in paragraph 2 of Art. 10 (Dividends) of the tax treaty between Countries S and B?..Read more

Foreign tax credit: Some interesting Indian judicial precedents
This article covers some interesting Indian judicial precedents on the issue of foreign tax credit...Read more

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COMMENTARY


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