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Recent Articles
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
More Articles
Recent Presentations
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’??
More Presentations
Videos
INTERNATIONAL TAX
Can subsequent domestic tax law amendments govern tax treaty interpretation? (Danish SC decision)
INTERNATIONAL TAX
Tax treaty treatment of oil & gas royalties: immovable property income (Art. 6) or business income (Art. 7)?
INTERNATIONAL TAX
EPC Contracts Controversy: Is income from supervision activities fees for technical services (FTS)?
INTERNATIONAL TAX
Can the tax authorities disregard a tax residence certificate (TRC)?
INTERNATIONAL TAX
Winning the Knowledge Management Challenge
INTERNATIONAL TAX
Can competent authorities' resolutions under mutual agreement procedure (MAP) bind courts?
INTERNATIONAL TAX
Canadian Supreme Court's landmark decision on GAAR
INTERNATIONAL TAX
Can an ordinance override a tax treaty?
INTERNATIONAL TAX
Are Luxembourg SICAVs entitle to tax treaty benefits?
INTERNATIONAL TAX
Stock Options: Tax Treaty Controversy
INTERNATIONAL TAX
Triangular cases: Can one tax treaty cancel out benefits under another tax treaty?
INTERNATIONAL TAX
Beneficial Ownership: The Danish Supreme Court's recent landmark decision (Part 1/2)
INTERNATIONAL TAX
Beneficial Ownership: The Danish Supreme Court's recent landmark decision (Part 2/2)
INTERNATIONAL TAX
Danish Ruling: Warehouse could not give rise to a PE
INTERNATIONAL TAX
Beneficial Ownership - can that requirement be impliedly read into the capital gains article in tax treaties?
INTERNATIONAL TAX
Permanent establishment and income attribution: Indian Supreme Court's landmark decision
INDIA TAX
Income definition: Accrual of income and the real income theory - issues and intricacies (Ep. 7)
INDIA TAX
Income definition: Accrual of income and the real income theory - issues and intricacies (Ep. 8)
INTERNATIONAL TAX
Could an E-commerce Fulfilment arrangement give rise to a PE?
INTERNATIONAL TAX
Tax treaty definition of 'royalties': Customized software and source code
INTERNATIONAL TAX
Could payments for customized software amount to 'royalties' under tax treaties?
INDIA TAX
Income definition: Accrual of income and the real income theory - issues and intricacies (Ep.4)
INDIA TAX
Income definition: Accrual of income and the real income theory - issues and intricacies (Ep.5)
INDIA TAX
Income definition: Accrual of income and the real income theory - issues and intricacies (Ep.6)
INDIA TAX
Accrual of income and the real income theory: Issues and intricacies (Ep.1)
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