Presentations

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