The Indian Supreme Court’s landmark decision on the MFN clauses concerning dividends taxation under the tax treaties
Oil and Gas Royalties: Income from immovable property or business income? (A UK court just answered that question)
Beneficial Ownership: The Danish Supreme Court's landmark decision
Can subsequent domestic tax law amendments govern tax treaty interpretation? (Danish SC decision)
Tax treaty treatment of oil & gas royalties: immovable property income (Art. 6) or business income (Art. 7)?
EPC Contracts Controversy: Is income from supervision activities fees for technical services (FTS)?
Beneficial Ownership: Reference to the domestic tax law rejected? ? ?
Sec. 263 of the IITA1961:? Can commissioner expand scope of the original assessment??
Forex Gains from Currency swap: ? Was it ‘income from immovable property’??
Could a warehouse cause a fixed place PE? ?
Payments for support services: ? Were they FTS?? Royalties and FTS (Article 12)?
Payments for Software installation and training:? Fees for Included Services under tax treaty?? ? Royalties and FTS (Article 12)?
Article 12? Tax treaty characterization: Payments under royalty-free license arrangements?
Time Charter v/s Royalty ? Shipping, Inlands Waterways and Air Transport (Art. 8) ? Royalties and FTS (Art. 12)?
Non-discrimination & Imputation Credit: A Landmark Decision
Liable to tax requirement: Could tax treaties prevent current and potential double taxation?
Art. 12 of tax treaties and the 'make available requirement': An interesting judicial precedent
Art.5 of the tax treaties and dependent agency PE: An interesting judicial precedent
Landmark Judgement of Italian Supreme Court: Could mere existence of subsidiary in Source State give rise to PE?
French Supreme Court's Landmark decision on Subsidiary PE.
Swiss Court's decision on Subsidiary as PE: Could representative office amount to PE?
French Supreme Admin. Court's Landmark Decision on Construction PE: Could duration of multiple projects be aggregated?
Permanent Establishment: Landmark Decision on The Commissionaire Arrangement
Important Australian Court's Decision : Characterization of Business Income v/s Capital Gain
Important Danish Supreme Court's Decision on Income Characterization: Business Income versus Income from Immovable Property.
German Federal Tax Court's decision: Place used to provide service amounts to fixed place PE.
Important Canadian Decision: Exhibition area amounts to permanent establishment or not.
Construction/ Installation PE: Could Software Installation Activity Give Rise to PE?
A landmark court decision of global significance: Could outsourcing lead to a permanent establishment?
Dependent Agency PE: Authority to conclude contracts - interesting Canadian decision
Important Australian Decision On Place Of Effective Management: Is Location Of A Company's Board Meetings A Determinative Factor?
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