Beneficial ownership test under article 12 of Canada-UK DTA
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 …
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 …
In certain countries, domicile of an individual is one of the factors for determining the scope of taxation …
Clarification on whether TDS is required to be deducted under section 195 of the Income Tax Act, 1961