Last month my blog discussed the questions relating to corporate residence and article 4(1) of the UK-US Double Tax Treaty raised in G E Financial Investments v HMRC [2021] UKFTT 210 (TC). This…
On 20 May, 2021 the first Webinar of IFA’s online series “A conversation on International Tax Practice” was held. Chaired by Robert Danon (Chair IFA Permanent Scientific Committee), global experts…
In one of the significant and eye-catching moves by the Indian government, the controversial law on retrospective tax on indirect transfer of shares representing assets held in India was withdrawn…
The present article explores some concrete application cases of Big Data in Tax Administrations (TAs). It then formulates some ideas for its possible expansion in the near future, considering both…
Mukesh Butani, Seema Kejriwal & Ajitesh Dayal Singh
Introduction
The Supreme Court of India recently settled a two-decade old dispute pertaining to taxability of software income. The Supreme Court…
Introduction
India’s 2021 Finance Bill proposes to add a definition of “liable to tax” in its domestic direct tax law. As per the definition, the term ‘liable to tax’, “in relation to a person, means…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
Introduction
One of the key reasons highlighted by OECD imploring the urgent need for consensus on digital tax under its Inclusive Framework were the repercussions arising on account of unilateral…
In international customary law, the scope of bilateral tax conventions is not exhaustive and instead limited by the temporal scope set out in ‘taxes covered’ clause. It is true that the scope of such…
