India
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
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Sponsored by Dhruva AdvisorsThe Income-tax Act, 1961 was amended in 2012 such that non-resident taxpayers are not entitled to claim relief under a tax treaty unless they obtain a tax residency certificate (TRC) from their country of residence. But a recent court ruling has changed the situation. -
Sponsored by Dhruva AdvisorsLitigation in respect of when a non-resident has a permanent establishment (PE) in India has always been a contentious issue.
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Sponsored by Dhruva AdvisorsRecently, 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]').
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