Bilateral tax treaties prevent double taxation in several ways. One is by identifying a taxpayer’s residence (“treaty residence”) and reserving taxing rights to that state alone. Anti-abuse rules ask…
In order to appreciate the importance of the international trade to economic development, it is pertinent to note the observation of Joseph Stiglitz in his book titled "Globalisation and it’s…
On December 30th of last year, the Indian Income Tax Appellate Tribunal was the first “quasi judicial institution” to apply the PPT to a treaty-shopping arrangement.[1] The case concerned a dispute…
Switzerland has suspended the application of the most favoured nation clause contained in the protocol to its 1994 tax treaty with India. This was done in response to the Supreme Court of India’s…
Introduction
The anti-profiteering law[1] under the Goods and Services Tax law (‘GST’) in India has been a subject matter of debate since the time GST was introduced. More than a hundred petitioners…
Buoyed by a transcendental approach to propel India towards “all-round, all-pervasive, and all-inclusive development”[1], India’s Finance Minister, Ms Sitharaman heralded the interim budget,…
In the ruling administration’s last full budget before India goes to the polls, India’s Finance Minister, Ms Sitharaman, laid out the government’s vision - “Making India a technology-driven and…
When India’s Finance Minister rose before the Lok Sabha (House of Commons) on 1st Feb, 2022 to present her budget for India’s fiscal year 2022-23 (April 1, 2022 to March 31, 2023), she compressed the…
Though India has been having tax treaties with over 90 countries across the globe for several decades now, interpretation of various provisions of the treaties continues to be a subject matter of…
A conversation on International Tax Practice culminated into an IFA webinar series on May 20th with global experts sharing their perspectives on landmark treaty and transfer pricing rulings…
