Non-applicability of LOB clause under India-UAE tax treaty and Relevance of timing as to when the application of LOB to a tax-treaty needs to be referred (Mumbai Tribunal)
May 23, 2021Under the context of tax treaties, application of a Limitation of Benefits (LOB) clause would result into denial of treaty benefits if main purpose of the transaction or one of the main purposes of the transaction is to obtain a treaty benefit. In the backdrop of businesses growing in multi-folds the Governments across the globe […]
Application of MFN clause under a tax treaty : Relevance of a third country being a member of OECD on the date of signing of tax treaty and whether a specific notification required to make MFN effective (Delhi High Court)
May 9, 2021Under the context of tax treaties, an MFN clause is incorporated where one of the contracting countries decide to grant MFN status to the other contracting country in relation to specified income streams. The residents of the MFN country are given the same beneficial treatment that India has extended to a resident of a third […]