Cross-border transactions and interpretation of related international tax treaties often involves controversies and issues concerning interpretation of treaty provisions and thereby leads to litigation with tax authorities. A recent judgment of the Tax Tribunal (Tribunal) in India in the case of Apollo Hospital Enterprises Limited (AHEL), has given rise to a debate regarding the interpretation of the expression “may be taxed” used in the India – Sri Lanka double taxation avoidance agreement (Treaty). Sanjay Sanghvi and Ashish Mehta, of Khaitan & Co, explore the implications.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR