Beneficial ownership test under article 12 of Canada-UK DTA
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Dependent personal services” article of Germany-France DTA Facts: The appellants are a married couple who were jointly taxed in Germany.
Dependent personal services” article of Germany-France DTA Facts: The appellants are a married couple who were jointly taxed in Germany.
Capital nature of the dividends!! Facts: The years in dispute are 2011 to 2016. The appellant is an individual and a tax resident of the UK.
Fixed place PE – Germany-UK DTA Facts: The appellants were tax residents of Germany and formed a general partnership in the UK in September 2007.
Pension taxability – Netherlands-Belgium DTA Facts: In 2019, the appellant was a tax resident in Belgium and received pensions that accrued and originated in the Netherlands based on past duties performed.
Beneficial ownership test under article 12 of Canada-UK DTA
Capital gains tax – situs of loan notes – meaning of “registered debentures” – non domiciled individuals
Demerger – tax neutrality under anti-avoidance lens & burden of proof!!
GAAR/SAAR Vs arm’s length – GAAR wins!!
Context is supreme! Customary International law – Common interpretation through subsequent practice!!
Is the decision on FTC correct? – Critical analysis In the case of Canon India, the company was incorporated and considered a tax resident in India for the fiscal year 2003-04.
A non-resident E-commerce operator supplies goods in India to the customers in India.
In the last couple of years, it may be perceived that corporates are devising ways to restructure their operations globally.
In certain countries, domicile of an individual is one of the factors for determining the scope of taxation of such individual in that country.