Tag Archive | international tax

INDIA: Taxability of overseas share sale – India influences African Tax Administrations

Since the 2012 Union Budget specified that shares of a foreign company would be deemed to be situated in India if it derives its value “substantially” from assets located in India, there has been uncertainty over what this really means. A recent case clarifies the matter. Delhi High Court clarifies taxability of overseas share sale […]

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Posted in Africa, Transfer Pricing

AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following extract from the IBFD Book – Arbitration under Tax Treaties: http://www.ibfd.org/sites/ibfd.org/files/content/pdf/ArbitrationunderTaxTreaties_sample.pdf This will complement the provisions of the mutual agreement procedure, which correspond exactly to the wording of Article 25(1) to (4) OECD Model, by adding the following paragraph (5): […]

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Posted in Africa, FP News