Tax Treaties

Limited Liability Companies have become one of the most common forms of business organisation in the United States. Their main attraction is a combination of limited liability for LLC members and…

“The judge who always likes the results he reaches is a bad judge,” Justice Antonin Scalia had famously said. A recent ruling delivered by the Bengaluru Bench of the Indian Income Tax Tribunal in ABB…

Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the…

On June 7, 2017, India joined more than 65 countries in signing the OECD’s Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) recommendations. The…

There is no doubt that 7 June 2017 is a day that will be a milestone in the history of international tax law. Signature of the Multilateral Convention to Implement Tax Treaty Related Measures to…

As widely reported by the news media, a major corporate tax reform has been under discussion in the United States, which may cause spillover effects on taxpayers engaged in cross-border transactions…

As a member of the Organization for Economic Co-operation and Development (“OECD”) Mexico[1] has been actively involved in the design and development of the Base Erosion and Profit Shifting (BEPS)…

On 24 April 2017 the Indian Supreme Court held that Formula One World Championship Ltd, the holder of the commercial rights to the Formula One Grand Prix, had a permanent establishment in India at…

If there was ever a need to demonstrate the need to improve international tax dispute resolution mechanisms, it was as a speaker at the TP Minds conference earlier this month. In the course of our…