Articles

India Tax

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  India-Mauritius tax treaty: is a tax residence certificate (TRC) sacrosanct for capital gains exemption under Art. 13(4)?
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  Virtual PE: The Indian tax authorities’ approach and judicial developments
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  Tax Residence Certificate (TRC): Is the Indian Finance Ministry’s 2013 press release binding on the tax authorities?
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  ITAT’s recent decision on India-Mauritius tax treaty Art. 13(4): Could the Indian tax authorities invoke GAAR and Limitation of Benefits (LOB) provisions?
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  The domain name registration controversy: Is it 'royalty'?
• The Indian Supreme Court’s landmark decision on the MFN clauses concerning dividends taxation under the tax treaties
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  Oil and Gas Royalties: Income from immovable property or business income? (A UK court just answered that question)
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  Beneficial Ownership: The Danish Supreme Court's landmark decision
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  Danish Supreme Court's interesting decision on income characterization: Business profits or income from immovable property?
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  A landmark Netherlands court decision on tax treaties: Can competent authorities reallocate taxing rights through Mutual Agreement Procedure (MAP)?
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  Could transfer pricing adjustments and interest-free loans lead to dividend income characterization under tax treaties?
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  Swiss landmark decision: Could a company's ultimate parent entity be regarded as a 'shareholder' for tax treaty purposes?
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  Could share buy-back proceeds be characterized as dividend income for tax treaty purposes?
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  Art. 10 (Dividends): Indian ITAT’s special bench decision on dividend distribution tax (DDT) – why is it likely to be reversed by a High Court?
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  “May be taxed” versus “shall be taxed” in tax treaty context: A landmark court decision from Canada
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  Art. 4(1) and ‘the liable to tax requirement’: Some landmark court decisions from Belgium and Canada
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  Non-discrimination provisions in tax treaties: A landmark Canadian decision on post-amalgamation loss carry-forward
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  Can consideration for outright transfer of know how be characterized as royalty under an applicable tax treaty?
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  Danish Supreme Court’s interesting decision on income characterization: Business profits or income from immovable property?
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  Permanent establishment (PE) and disposal test: Existence of PE denied on the basis of the ‘Formula One Case’
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  MFN clauses in tax treaties: The Indian ITAT reads the 'make available' requirement from India-Portugal tax treaty into the India-Sweden tax treaty
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  Income characterization issues under tax treaties: some landmark judicial precedents
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  Construction PE in case of multiple projects: Stand-alone or aggregate approach?
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  Prerequisites for dependent agency PE under tax treaties: Some important judicial precedents
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  Variable interest on loans: Tax treaty characterization as dividends (Art. 10) or interest (Art. 11)?
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