Sanjeev Sharma, principal director of income tax at the India Income Tax Department, looks at the implications of the Concentrix case for multinational companies investing in India.
Sanjeev Sharma, principal director of income tax at the India Income Tax Department, explains how the Supreme Court’s ruling on software licensing fees interpreted the application of tax treaties, the OECD Model Tax Convention, Income Tax Act and Copyright Act.
Sanjeev Sharma, principal director of income tax at the India Income Tax Department, explains why the Madras High Court decided Redington India’s use of foreign subsidiaries to transfer shares offshore was an attempt to avoid capital gains tax and transfer pricing rules in India.
Sanjeev Sharma, principal director of income tax at the India Income Tax Department, discusses the exchange of tax information developments of the past decade and what needs to happen next.
Sanjeev Sharma, principal director of income tax (investigation) at the India Income Tax Department, discusses recent court decisions in India concerning the scope of ‘preparatory’ and ‘auxiliary’ activities.
Sanjeev Sharma, principal director of income tax (investigation) at the India Income Tax Department, considers how the ‘preparatory’ and ‘auxiliary’ test has become difficult to apply, despite amendments to the OECD and UN model tax treaties, as well as the MLI.