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Developments

Permanent Establishment (PE): Burden Of Proof

August 23, 2017

 Who bears the burden? Is the taxpayer required to prove absence of a PE? Or Should the Source State's tax authorities prove existence of a PE?

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The United Kingdom Is Likely To Reject BEPS Action Item 7 Recommendation Targeting Commissionaire Arrangements

By Dr. Amar Mehta  -  January 6, 2017

 That could be a significant twist in the BEPS project.

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Indian Equalisation Levy On Payments For Online Advertisement Services Comes Into Effect

By Dr. Amar Mehta  -  June 1, 2016

The Indian Equalisation Levy at the rate of 6% of the gross payment came into effect from 1 June 2016.

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Recent Blog Articles

  • Can beneficial ownership requirement be (impliedly) read into Art. 13 (Capital gains) of tax treaties?
  • Some interesting precedents: Existence of fixed place permanent establishment denied due to short activity-duration
  • Could A Foreign Enterprise's Maintenance Activities Lead To An Installation PE?
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Recent Presentations

  • Landmark Judgement of Italian Supreme Court: Could mere existence of subsidiary in Source State give rise to PE?
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