Is the decision on FTC correct? – Critical analysis In the case of Canon India, the company was …
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 …
Interpreting the words “incidental to” Facts: The disputed years are 2014 and 2015.
I don’t think so! The key difference lies in the technical explanations of the India-US DTA and Ireland-US …
Liable to tax” – Non-discrimination clause – Irish group relief – USA-Ireland DTA Facts: Two Irish subsidiaries were …
Article 15 of France-UK DTA – Dependent personal services – published on 11 April 2025 Facts: The years …
Can foreign PE be considered as employer under the treaty? Facts: A company incorporated in Germany maintained foreign …
What about foreign losses? The participation exemption was introduced into Irish tax law by the Finance Act 2024.
