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S&R Associates
The primary purpose of double taxation avoidance agreements ("DTAAs") is to eliminate double taxation by providing taxing rights or granting tax credit...
Majmudar & Partners
The Gujarat High Court (the "HC"), in a recent ruling (the "HC Ruling"), dismissed the Indian tax department's (the "ITD") appeal against a Tribunal Ruling allowing the taxpayer...
Lakshmikumaran & Sridharan
Revenues earned by MNCs from India often remain under the lens of the Indian taxation authorities for examination of constitution of Permanent Establishment...
Acuity Law
Indirect transfer controversy has been the most discussed issue in the Indian tax ecosystem. It began when Vodafone International Holdings Ltd acquired an indirect holding in an Indian entity...
Nexdigm Private Limited
Determination of market value in an inter-unit transfer in the context of profit-linked incentive deduction - end to disputes or beginning of new one?
Acuity Law
The Hon'ble Supreme Court of India (Apex Court) has recently pronounced a landmark ruling[ᶦ] on treaty interpretation with a specific reference to Most Favored Nation...
Metalegal Advocates
The Base Erosion and Profit Shifting project, initiated by the OECD in 2013, aimed to combat tax avoidance strategies employed by multinational enterprises and promote equitable international tax practices.
Nexdigm Private Limited
In legal terms, the Most Favored Nation (MFN) clause in international trade agreements mandates that a country must treat all its trading partners equally...
Khaitan & Co LLP
In a significant judgment that can have far-reaching ramifications concerning interpretation of Double Taxation Avoidance Agreements (DTAA), the Supreme Court of India, in a group of matters...
Nexdigm Private Limited
In a seminal judgment, the Division Bench of the Supreme Court ruled in favor of the Revenue in a protracted and contentious dispute concerning the Most Favored Nation (MFN) clause in the tax treaties.
Lakshmikumaran & Sridharan
Over the past few years, the Foreign Direct Investments (‘FDI') in India have been on a steep rise. As per the 2023 edition of the World Investment Report...
Nexdigm Private Limited
In the current era of globalization of businesses, interdependence among group companies has become more common.
Khaitan & Co LLP
Per the extant India-Mauritius tax treaty ("Tax Treaty"), capital gains on sale of Indian company shares (acquired prior to 1 April 2017) and sale of derivatives...
LEGALLANDS LLP
"Vasudha-Iva Kutumba-Kam (Sanskrit: वसुधैव कु टुम्बकम) - The Whole World is ONE FAMILY." The phrase has become most relevant in reference to present day world economics.
Nexdigm Private Limited
We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of May 2023.
Nexdigm Private Limited
技術サービス料およびロイヤルティ(特許権使用料の支払い)に対 する源泉徴収率引き上げの影響
Nexdigm Private Limited
The taxation of dividends underwent a change when in Finance Act 2020, dividends were made taxable in the hands of shareholders. Prior to this, since 1997, the dividend-paying...
Nexdigm Private Limited
The assesses considered the payment to the overseas company as reimbursement of salary costs not liable to tax in India in the absence of any income element.
S&R Associates
The Ministry of Corporate Affairs ("MCA") notified Section 234 of the Companies Act, 2013, as amended (the "Companies Act"), and Rule 25A of the Companies (Compromises, Arrangements and Amalgamations)...
Nexdigm Private Limited
We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of March 2023.
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