In the second part of her analysis of Caterpillar’s tax affairs following the company’s appearance before the Senate Subcommittee on Investigations, Mirna Screpante, tax researcher, looks at the division between the location of activities and the location of taxable profits and proposes a method for determining economic substance.
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Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
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