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Direct Tax

India’s pillar two pledge may have limited impact, experts warn

With corporate tax rates already exceeding 15%, India will need to think creatively to extract additional revenue through new pillar two rules, local partners tell ITR

Tom Baker, July 22 2024

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India: Tribunal rules on agency permanent establishment and profit attribution

Recently, the Income Tax Appellate Tribunal gave an important judgement regarding the creation of and attribution of profits to an agency permanent establishment (Agency PE) – Daikin Industries v ACIT ('ITA No 1623 of 2015 [New Delhi Income Tax Appellate Tribunal, May 28 2018]').

Hariharan Gangadharan, July 12 2018
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India: Supreme Court rules on the tax implications of loan waivers

The issue of whether a waiver of loans results in taxable income for the borrower has been a controversial one in India.

Hariharan Gangadharan, May 29 2018
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Indian Supreme Court: dominant purpose of investment is irrelevant in determining whether expenditure is ‘in relation to’ exempt dividend income

Indian law provides that the dividends paid by domestic companies to their shareholders are liable to a dividend distribution tax at the company level. As a corollary, such dividends are exempt in the hands of shareholders, subject to certain exclusions.

Hariharan Gangadharan, April 30 2018

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