Differing tax treaty definitions, or the lack of them, mean that the term ‘operation of ships/aircrafts in international traffic’ has caused controversy for India’s taxpayers, explain Ajit Kumar Jain, Kanchana Ramamurthi and Mehul Jain of BMR & Associates.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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