India: Tax Treaties

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

India's APA Programme Records Landmark Growth In FY 2024-25 – 7th Annual Report

The Central Board of Direct Taxes (CBDT) released its 7th Annual Report on the Advance Pricing Agreement (APA) Programme for FY 2024–2025, marking a record year in terms of agreements signed, bilateral cooperation, and tax certainty.

NP

Nexdigm Private Limited

An Indirect Transfer In An Offshore Two-tier Structure Is Not Taxable In India – Tax Tribunal Rules In EBay-Flipkart Case

In eBay Singapore Services Private Limited v. DCIT, [TS-1343-ITAT-2025(Mum)], the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) ruled that capital gains arising to a Singapore tax resident...

KC

Khaitan & Co LLP

Separate Notification Required To Invoke MLI

The Delhi Bench of Income-tax Appellate Tribunal (ITAT) in the case of Kosi Aviation Leasing Ltd. (Taxpayer)[1] v. ACIT, has held that single omnibus notification under section 90(1) of the Income-tax Act...

AM

Alvarez & Marsal

Cross-Border Strategies For Founders In SEA And India On Leveraging Convertible Notes

In the dynamic start-up landscapes of Southeast Asia (SEA) and India, convertible notes have become a favoured tool for initial fundraising efforts.

India Commercial

LP

Legitpro Law

Singapore vs. India: Tax Planning And Business Structuring For Growth

IMC Group

MLI Provisions Unenforceable Without Separate Notification: Mumbai ITAT Rejects Tax Authority's Attempt To Deny DTAA Benefit Using Principal Purpose Test

AM

Alvarez & Marsal

India May Have A Case: Evaluating Jane Street's PE Exposure Amid Derivatives Crackdown

BA

BTG Advaya

Investment Vehicles

GA

Globeview Advisors LLP

Transfer Of Rights Entitlement Is Not Akin To Transfer Of Shares

AC

Aurtus Consulting LLP

To Report Or Not To Report, That Is The Branch Office Question

LS

Lakshmikumaran & Sridharan

India's Evolving Approach To Dispute Resolution In Bilateral Investment Treaties

India Litigation

SO

S&A Law Offices

Tribunal Rejects Lifting Of Corporate Veil And Affirms Taxpayer Is Not The Beneficial Owner Of Foreign Assets Owned By A BVI Company

KC

Khaitan & Co LLP

Section 194T – A New Compliance Frontier For Partnership Firms And LLPs

LS

Lakshmikumaran & Sridharan

CBDT Signs Record 174 APAs And First Ever Multilateral APA In FY 24-25

NP

Nexdigm Private Limited

RBI MPC October 2025: Repo Rate Unchanged At 5.5% Amid Balanced Growth And Inflation Outlook

India Government

LP

Legitpro Law

Decoding The India–UK CETA: An Overview Of Trade, Services And Compliances

Worldwide International

RL

RPV Legal

ESG Compliance & Corporate Governance: Regulatory Shift In 2024-25

India Commercial

Ka

Khurana and Khurana

RBI Master Direction On Regulation Of Payment Aggregators, 2025: Analysis Of Key Developments

I

CMS INDUSLAW

GST On Legal Services & Advocate Fees Explained

V

Vakilsearch

Tax Street – February 2025

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 February 2025.

NP

Nexdigm Private Limited

CBDT Issues Guidance On The Application Of Principal Purpose Test (PPT) Under Tax Treaties

Upon the Multilateral Instrument (MLI) entering into force, PPT has been introduced as a minimum standard in India's tax treaties covered by the MLI.

AC

Aurtus Consulting LLP

Supreme Court Has Stayed Order Passed By Delhi High Court In Case Of Tiger Global International Holdings

The matter decided by Hon'ble Delhi High Court in the case of Tiger Global International III Holdings versus The Authority for Advance Ruling dated 28.08.2024...

DC

Dewan P.N. Chopra & Co.

Tax Treaties And The Principal Purpose Test – Government Clarifies Its Application

India is a signatory to the Multilateral Convention to Implement Tax Treaty Related Provisions to Prevent Base Erosion and Profit Shifting ("MLI").

Anagram Partners

Government Issues Guidance On Application Of 'Principal Purpose Test' Under Tax Treaties

KC

Khaitan & Co LLP

ITAT Ruling In The Case Of SC Lowy

VA

Vaish Associates Advocates

ITAT Delhi Examines Principal Purpose Test And Allows The Benefit Under India-Luxembourg Tax Treaty

KC

Khaitan & Co LLP

Taxing Buy-Back Of Shares| Creating An Artificial Quagmire

Anagram Partners

Switzerland Suspends Application Of Most Favoured Nation (MFN) Clause For India-Switzerland Tax Treaty

NP

Nexdigm Private Limited

Swiss Authorities Suspend MFN Clause From Tax Treaty With India

DC

Dewan P.N. Chopra & Co.

Tax Street - September 2024

NP

Nexdigm Private Limited

Tax Considerations In Cross Border M&A | An In-Depth Overview Of The Indian Landscape

BA

BTG Advaya

Fate Of Indirect Transfer Tax Post Tiger Global Judgment – Will It Add Hurdles For MNEs?

LS

Lakshmikumaran & Sridharan

US Limited Liability Company Is Eligible To Claim India-US Tax Treaty Benefit – Delhi ITAT

KC

Khaitan & Co LLP

Tax Street - September 2024

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 September 2024.

NP

Nexdigm Private Limited

Tax Considerations In Cross Border M&A | An In-Depth Overview Of The Indian Landscape

Cross-border Mergers and Acquisitions (M&A) demand planning and structuring across multiple dimensions, with tax being a crucial element.

BA

BTG Advaya

Fate Of Indirect Transfer Tax Post Tiger Global Judgment – Will It Add Hurdles For MNEs?

Recently, the High Court of Delhi delivered a ruling marking significant victory for international investors. The High Court reversed the findings of the Authority of Advance Ruling ('AAR') in the case of Tiger Global.

LS

Lakshmikumaran & Sridharan

US Limited Liability Company Is Eligible To Claim India-US Tax Treaty Benefit – Delhi ITAT

In the case of General Motors Company USA v Assistant Commissioner of Income Tax – Circle (International Taxation), 2024 166 taxmann.com 170 the Delhi bench of the Income Tax Appellate Tribunal (ITAT)...

KC

Khaitan & Co LLP

Eligibility Of US Based Limited Liability Company To Avail Benefits Under The India-USA DTAA

VA

Vaish Associates Advocates

Tax Street – June 2024

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...

NP

Nexdigm Private Limited

The Reverse Flip Gambit: Legal And Tax Manoeuvres For Indian Startups Coming Home

India's startup environment is a breeding ground for innovation and growth, luring companies to return home.

India Commercial

LS

Lakshmikumaran & Sridharan

Supreme Court Of India's Ruling On The 'Most Favoured Nation' Clause In Tax Treaties - A Compelling Case For Review !!!

The Supreme Court of India in the case of Assessing Officer vs. M/s Nestle SA and Others, elucidated law relating to applicability of the Most Favoured Nation clause in the protocol(s) for availing benefit of a DTAA ...

VA

Vaish Associates Advocates

Indian Government Notifies A Lower Rate Of Tax For Fees For Technical Services And Royalty Under India-Spain DTAA

Recently, in a significant ruling of Nestle SA, the Supreme Court of India had examined the interpretation of the Most Favoured Nation (MFN) clause in Indian treaties with OECD member countries.

Atharv Advisors

Legislative Precision: India's BEPS Response And International Tax Reforms

MA

Metalegal Advocates

Decoding The Nexus Of Economic Loyalty & Profit Attribution To Permanent Establishments

MA

Metalegal Advocates

Arm's Length Principle In Transfer Pricing: A Conceptual Analysis

MA

Metalegal Advocates

India Amends Its Tax Treaty With Mauritius, Adds Anti-Abuse Conditions

KC

Khaitan & Co LLP

Tribunal Emphasizes Importance Of TRC: Upholds Eligibility Of Mauritius Based CIV For Tax Treaty Benefits

Parakram Legal

Mauritius And India Signed New Tax Treaty Protocol

TS

The Sovereign Group

Private Equity And M&A In India: What To Expect In 2024?

India Commercial

ND

Nishith Desai Associates

Disallowance Under Section 40(a)(i) On Payment Made To Non-residents – Whether Violative Of Non-Discrimination Article In Tax Treaty?

LS

Lakshmikumaran & Sridharan

Indian Tax Treaties: Capital Gains And Beneficial Ownership Test

SA

S&R Associates

How A Clerical Error Led To Substantial Tax Litigation.

India Litigation

MP

Majmudar & Partners

Interplay Between Foreign Taxpayers' Global Profits And PE Profit Attribution

LS

Lakshmikumaran & Sridharan

Indirect Transfers – Evolution Of Law & Recent Dicta

A

Acuity Law

Tax Street – November 2023

NP

Nexdigm Private Limited

"Most Favored Nation" Clause – Important Ruling Of The Hon'ble Supreme Court Of India

A

Acuity Law

BEPS Actions – A Concise Summary

MA

Metalegal Advocates

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Latest Videos

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#TaxMantra | AAR To BAR - A Quantum Change

VA

Vaish Associates Advocates

Webinar: India Mauritius Tax Treaty Amended (Capital Gains Tax Benefit Under Mauritius / Singapore Treaties Fall Away): Impact On India Focused Funds And PE/M&A Structures (May 12, 2016) (Video Content)

ND

Nishith Desai Associates

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