Switzerland has suspended the application of the most favoured nation clause contained in the protocol to its 1994 tax treaty with India. This was done in response to the Supreme Court of India’s judgement in Nestlé.[1] This action appears to have raised a number of legal questions with respect to reciprocity in tax treaty interpretation…
In this blog, I shall examine the policy and characteristics underlying the split-rate system of taxing corporate profits/income. I shall also discuss the issue whether the Indian Dividend Distribution Tax (DDT) represents an inverse split-rate applied to corporate profits/income, or if it is merely an independent levy, which is source-agnostic. Split-rates and their role in…
There has been much brouhaha about equalization levies in the context of the digital economy. One of the hotly debated issues is whether such levies are covered by tax treaties at all. In this post, I should like to reflect over this issue as objectively as possible. I shall not, however, delve into issues of…
