Article 13 India-Mauritius DTA – lifting corporate veil, substance over form, conduit arrangement
Article 13 India-Mauritius DTA – lifting corporate veil, substance over form, conduit arrangement
Word “business” interpretation under Article 18– Article 16 and 18 of Germany-Luxembourg DTA
Embedded royalty in bottling agreement with PepsiCo – whether royalty withholding tax payable
30% rule on employment income – Article 14 and 22 of Germany-Netherlands DTA
POEM interpretation – Article 13 read with Article 4 of UK-Mauritius DTA
PE profit computation, an interesting scenario – Netherland-Belgium DTA
Interest or dividend? – Netherlands-Brazil DTA Facts: The appellant, a Netherlands-based company, holds 99.9% interest in a Brazilian …
Pension taxability – Netherlands-Belgium DTA Facts: In 2019, the appellant was a tax resident in Belgium and received …
Fixed place PE – Germany-UK DTA Facts: The appellants were tax residents of Germany and formed a general …
