Kluwer International Tax Blog: Global Experts debate Landmark Transfer Pricing Cases in IFA Webinar
– Mukesh Butani & Seema Kejriwal On 20 May, 2021 the first Webinar of IFA’s online series “A conversation on International Tax Practice” was held. Chaired by Robert Danon (Chair IFA Permanent Scientific Committee),...
Mint: We will eliminate double taxation, says OECD tax chief
-Mukesh Butani We need to design the rules on global minimum taxes for implementation, to finalize this political agreement by October, says Pascal Saint-Amans, Director of OECD’s Center for Tax Policy and Administration...
Kluwer International Tax Blog : India’s Supreme Court finally settles a two decade old dispute on software taxation
Mukesh Butani, Seema Kejriwal, Ajitesh Dayal Singh Introduction The Supreme Court of India recently settled a two-decade old dispute pertaining to taxability of software income. The Supreme Court ruled that payments to...
The Financial Express: Supreme Court on software taxation: A torch-bearing verdict in the tax-treaty space
By Mukesh Butani & Tarun Jain Whether the licence to use computer software is a transfer of copyright was the core issue before the Supreme Court in the case of Engineering Analysis and a batch of over 80 appeals that was...
Financial Express: Tax matters: The Cairn conundrum and the future of tax arbitration
By Mukesh Butani & Aparna Raman The arbitration ruling by the Permanent Court of Arbitration (PCA) in the Cairn Energy case, coming just three months after the Vodafone ruling, is testimony that jurisdiction is and will...
Vodafone and India’s Offshore Indirect Transfer Tax: The saga continues
Vodafone and India’s Offshore Indirect Transfer Tax: The saga continues Background In September 2020, the Permanent Court of Arbitration at The Hague issued award in favor of Vodafone[1] against India’s income tax...
Kluwer’s Blog: United States’ 301 findings on India’s Equalisation Levy – What next!
Introduction One of the key reasons highlighted by OECD imploring the urgent need for consensus on digital tax under its Inclusive Framework were the repercussions arising on account of unilateral digital taxes. Recent reports...
The Coca-Cola Company Ruling – Analysing the US Tax Court’s observations
Purpose of the blog: To analyze the recent ruling of the US tax court (‘the Court’) in the case of The Coca-Cola Company (TCCC). Ruling: The US Tax Court, for the years 2007-09, ruled TCCC was under-compensated by its associated...
What next after the Vodafone tax arbitration?
The Permanent Court of Arbitration at The Hague has issued its award allowing the claim of Vodafone against the Government of India. The award marks the culmination of a long-drawn acrimonious litigation between Vodafone and the...
Is digital tax the end of Multilateralism as we know it?
Frustrated by the slow pace of discussions and anxious to mobilise revenue considering the Covid-19 pandemic, several countries have taken unilateral measures to tax the digital economy.