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A Recent Controversial Case: Can income from transaction (not involving activities in India) between two foreign companies be taxed in India?

January 28 2023

Open Access Video

This video deals with a recent decision of the Indian Income Tax Appellate Tribunal (ITAT) on the India-Singapore tax treaty. That decision could cause potentially significant tax litigation in respect of tax treatment of transactions between non-resident entities. The Indian tax authorities may seek to apply that decision to tax income from transactions - carried out outside India - between two or more non-resident companies. 

Case Notes (for patrons)

Indian ITAT holds that income from transactions between two Singapore companies was taxable in India. 

Danish court denies benefit of a tax treaty provision in case of back-to-back transactions

Broadcast reproduction right distinguished from copyright

Articles (for patrons and subscribers)

Opinion: Interplay between India-Netherlands tax treaty's Art. 10(2) read with MFN clause and implementation of MLI Art. 8(1) in the India-Slovenia tax treaty

Restrictive conditions in technology transfer agreements: impact on income characterization

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