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Searching Content indexed under Tax Treaties by Khaitan & Co ordered by Published Date Descending.
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Government Of India Ratifies MLI – Bringing India On The Cusp Of A New International Tax Regime
The Government of India (Union Cabinet) has approved the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and India's final position to the same.
India
18 Jun 2019
2
‘Management Fees' Constitutes ‘Business Income' In The Absence Of Specific FTS Provision In The Relevant Tax Treaty
The Bengaluru bench of the Income-tax Appellate Tribunal vide order dated 28 February 2019, held that consideration received by non-resident entity from an Indian company for performing management services ...
India
8 Apr 2019
3
India-Mauritius Tax Treaty: AAR Re-Iterates Need For ‘Substance'
India-Mauritius Tax Treaty has always attracted interest of international investor community as well as the tax authorities.
India
16 Mar 2018
4
Apex Court Provides Relief To The Outsourcing Sector On The Issue Of Permanent Establishment
The Supreme Court held that rendition of support services by Indian group company to its parent company in the US would not lead to creation of permanent establishment (PE) of the parent company in India in terms of India-USA Double Taxation Avoidance Agreement (DTAA).
India
15 Nov 2017
5
The Multilateral Instrument And Its Impact On India's Bilateral Tax Treaties
With an object to address aggressive tax strategies by multinational enterprises (MNE), the Organisation for Economic Cooperation and Development (OECD) had undertaken the landmark Base Erosion and Profit Shifting (BEPS) Project.
India
3 Jul 2017
6
Singapore Tax Treaty: Applicability Of ‘Remittance' Test Under LOB Clause To Capital Gains
The Mumbai Bench of the Income-tax Appellate Tribunal (Tribunal) in its ruling in Citicorp Investment Bank (Singapore) Ltd ([2017] 81 taxmann.com 368) has upheld the capital gains tax exemption...
Singapore
20 Jun 2017
7
SC Upholds Delhi HC Verdict - Racing Circuit Is PE Of Formula One
On 24 April 2017, the Apex Court upheld the decision of the Delhi High Court in the case of Formula One World Championship Limited v CIT, ...
India
8 May 2017
8
Rollback Provision Available In Respect Of Bilateral Advance Pricing Agreement Under The India-Korea DTAA
A revised DTAA between India and Korea for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to taxes on income was signed on 18 May 2015 and came into force on 12 September 2016.
India
4 Apr 2017
9
Reset & Restart-India's Changing Tax Tides
By way of a quick round-up, set out below are few key tax changes that will be / are proposed to be effective from 1 April 2017.
India
3 Apr 2017
10
CBDT Clarifies GAAR Implementation Through 16 Point FAQs
Inarguably one of the biggest tax reforms that the country has ever witnessed, the General Anti-Avoidance Rules inserted in Chapter X-A of the (Indian) Income-tax Act, 1961 are slated to take effect from 1 April 2017.
India
3 Feb 2017
11
Investment Funds – 2016 In Perspective, Budget Expectations 2017
In an audio-conference specially dedicated to funds and fund managers titled "Investment Funds: 2016 in Perspective, Budget Expectations 2017", we shall discuss several regulatory changes in 2016 . . .
India
10 Jan 2017
12
Revised India-Singapore Tax Treaty: Decoding The Third Protocol
Pursuant to the signing of the third protocol (Protocol) amending the India-Singapore Tax Treaty (Treaty) on 30 December 2016, the text of the Protocol has now been officially released...
India
4 Jan 2017
13
A New Year, A New Innings: After Mauritius & Cyprus, Singapore To Lose Capital Gains Tax Exemption
The capital gains exemption under the Treaty was made coterminous with that under the India-Mauritius tax treaty.
India
3 Jan 2017
14
Delhi HC: Racing Circuit Constitutes Permanent Establishment Of Formula One
Despite the huge success of the inaugural edition of the Formula One Grand Prix of India held in October 2011 and of the two iterations thereafter in 2012 and 2013 respectively...
India
3 Jan 2017
15
Cyprus Loses The ‘Non-Cooperative Jurisdiction' Tag
India had notified Cyprus as a ‘non-cooperative jurisdiction' owing to lack of effective exchange of information, vide a notification of the CBDT dated 1 November 2013 under Section 94A of the Income Tax Act, 1961, . . .
India
20 Dec 2016
16
AAR Rulings On Taxability Of Offshore Mergers And Eligibility Of Mauritian Company To Claim Treaty Benefits
The AAR, in the recent judgement of Banca Sella SpA, held that capital gains arising on amalgamation of a non-resident company, with its non-resident group entity would not attract capital gains tax in India...
India
20 Sep 2016
17
AAR Rulıngs On Interpretation Of MFN Clause And Taxatıon Of IPR Fail High Court's Litmus Test
The notification giving effect to the Protocol only referred to ‘lesser rate of tax' and did not include the ‘restricted scope of taxation' in relation to FTS.
India
8 Aug 2016
18
Mauritius Tax Treaty 2.0 - Equity Investments Out, Debt Investments In
An additional provision is also provided detailing the mechanism for the assistance in collection of taxes.
India
18 May 2016
19
Mauritius No Longer A ‘Sweet Spot'?
The Ministry of Finance, Government of India, has issued a Press Release on 10 May 2016 that marks a watershed moment in India's quest with tax avoidance and the ‘substance over form' debate.
India
13 May 2016
20
Madras High Court Decides Cyprus' Fate - Upholds The Validity Of Notification Of Cyprus As A 'Notified Jurisdictional Area'
It is peculiar to note that the tax authorities have challenged non-withholding of tax even when the transaction resulted in a capital loss to the Cypriot seller and thus, no taxable income arose in the hands of the Cypriot seller.
India
3 May 2016
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