Hariharan Gangadharan

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Indian tax treaty benefits available without providing a tax residency certificate

The 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.

Hariharan Gangadharan, October 15, 2018

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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

Mutual agreement procedures are on the up

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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

SC: dominant purpose of investment is irrelevant in determining whether expenditure is ‘in relation to’ exempt dividend income

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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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India: Indian budget 2018-19; Recent rulings on the India-Mauritius treaty

The Indian budget was presented on February 1 2018.

Hariharan Gangadharan, February 27, 2018

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India moves to revamp its direct tax law

The introduction of the goods and services tax last year has led to a consolidation of the indirect tax regime in India. The government is now moving to overhaul the direct tax regime.

Hariharan Gangadharan, January 30, 2018

Hariharan Gangadharan

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