Beneficial ownership test under article 12 of Canada-UK DTA
Demerger – tax neutrality under anti-avoidance lens & burden of proof!!
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 …
Clarification on whether TDS is required to be deducted under section 195 of the Income Tax Act, 1961
Is the decision on FTC correct? – Critical analysis In the case of Canon India, the company was …
A Limited Liability Company (LLC) was incorporated in the US and was wholly owned by a US corporation, …
Dual resident companies – Can TRC be rejected? In a recent case before India’s Tax Tribunal involving eBay …
Article 13 or Article 10? What if both articles Apply? I recently had an engaging conversation with a …
Liable to tax” – Non-discrimination clause – Irish group relief – USA-Ireland DTA Facts: Two Irish subsidiaries were …
