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.
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.
The OECD guidelines, which were updated in July 2017 to incorporate Action Plan 13 of the BEPS project, provide a minimum requirement of maintaining a three-tiered documentation system.
In an ex-parte interim order, the Delhi High Court restrained Vodafone from initiating or continuing arbitration proceedings under the India-UK investment treaty.