Worldwide: Tax Treaties

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Delhi ITAT Allows DTAA Benefit On DDT; Caps DDT At 10% Under Indo-Japan DTAA

The Hon'ble Delhi Income Tax Appellate Tribunal (hereinafter referred to as ‘Delhi ITAT') in the case of Mitsui Kinzoku Components India Pvt. Ltd. v. CIT (Appeals)...

AC

Aurtus Consulting LLP

PE Loss Set Off Against ECB Interest Allowed: Abu Dhabi Commercial Bank v. DCIT

Abu Dhabi Commercial Bank ("Assessee") is a UAE -headquartered bank and UAE tax resident with a Permanent Establishment ("PE") in India, extended External Commercial Borrowings ("ECBs")...

A

Acuity Law

Tax Residency Abroad – Not Just A Game Of Days Spent Outside India!

In a landmark ruling with far‑reaching implications for high‑net‑worth individuals and globally mobile Indian entrepreneurs, the Bangalore Bench of the Income Tax Appellate Tribunal (ITAT) has held that Mr. Binny Bansal...

NP

Nexdigm Private Limited

Indonesia's PMK No. 112 Of 2025: Procedures For Implementing Double Taxation Avoidance Agreements

On December 30, 2025, Indonesia issued Minister of Finance Regulation No. 112 of 2025 (PMK 112/2025), which entered into force on the date of promulgation.

AM

Alvarez & Marsal

Tiger Global Ruling: Does GAAR Override Tax Treaties And What Is The Way Forward?

R & D Law Chambers LLP

The Supreme Court Of India's Judgement In Tiger Global: Jarring Way Ahead For India-Mauritius Tax Treaty

HA

HSA Advocates

Tiger Global: Redefining Treaty Protection In India

I

CMS INDUSLAW

From Vodafone To Tiger Global — A Constitutional Reset

India Commercial

IL

IndiaLaw LLP

Legal Case Analysis: Tiger Global - Flipkart Tax Dispute

LP

Legitpro Law

Supreme Court Ruling In Case Of Tiger Global: Key Observations And Takeaways

AC

Aurtus Consulting LLP

Tiger Global After GAAR Treaty Shopping Tax Residency Certificates And What Investors Must Show

LP

Legitpro Law

Bombay High Court Resolves The DDT-DTAA Controversy: Treaty Rate Held Applicable Notwithstanding Domestic Levy Mechanism

LS

Lakshmikumaran & Sridharan

Tiger Global Before The Supreme Court: Redefining The Limits Of Treaty Protection, AAR Jurisdiction And Investor Certainty

KS

King, Stubb & Kasiva

Tax And Legal Implications Of Engaging Freelancers For Businesses In Thailand

GI

GRATA International

对赌规则的最新司法走向——浅析《公司法司法解释（征求意见稿）》

China Commercial

JT

Beijing Jincheng Tongda & Neal Law Firm

Employment law changes you should know about in 2026

Australia Employment

JH

Jewell Hancock

SEBI (Stock Brokers) Regulations, 2026: A Structural Reset Of India's Broking Regulatory Framework

India Commercial

IL

IndiaLaw LLP

RBI Releases FEMA 2026 Export-Import Trade Regulations: What Businesses Need To Know

India International

LS

Lakshmikumaran & Sridharan

Moving Towards Responsible And Ethical Use Of AI: Analysis Of India's Proposed AI Bill, 2025

India Technology

L

LexOrbis

Tax And Legal Implications Of Engaging Freelancers For Businesses In Tajikistan

In practice, an individual performing work outside the regular staff of an organisation and not employed under an employment contract is generally classified either as a contractor engaged under a civil law agreement...

GI

GRATA International

Supreme Court Denies India-Mauritius Tax Treaty Benefit For Tiger Global, Rejects Grandfathering Protection Under GAAR

In a landmark ruling, the Supreme Court of India has denied capital gains tax exemption claimed by Tiger Global International II Holdings, Tiger Global International III Holdings and Tiger Global International IV Holdings under the double taxation avoidance agreement between India and Mauritius on sale of shares of Flipkart Private Limited.

KC

Khaitan & Co LLP

Indian Court Reinforces Physical Presence As Cornerstone Of Service PE

The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don't count, potentially reshaping compliance for multinationals...

LS

Lakshmikumaran & Sridharan

Revisiting The Nature Of Dividend Distribution Tax In India

Dividend taxation in India has historically been one of the shifting and contested areas of direct taxation punctuated by doctrinal uncertainties, conflicting tribunal and court decisions and eventual legislative reforms.

LP

Legitpro Law

Litigation-Proof Cross-Border Tax & FDI Structuring Strategies: A Practical India Entry Playbook For Mid-Sized Groups

R & D Law Chambers LLP

The IRD's Guidance For Dual-resident Individuals Under The Double Tax Arrangement Between The Chinese Mainland And The Hong Kong SAR

KP

KPMG

Understanding The Nuances Of Taxation Aspects For Cross Border Transactions In India

AA

Ahlawat & Associates

Key Tax Impact Of Possible Revisions To The India-France Tax Treaty From A Foreign Portfolio Investor Perspective

AM

Alvarez & Marsal

Australian High Court's PepsiCo Decision: Key Tax Insights From Belgium And The Netherlands

LL

Loyens & Loeff

Remote But Relevant? – OECD's 2025 Update On 'Home' As A 'Place Of Business'

AP

AZB & Partners

Delhi High Court Upholds Non-taxability Of Fees Paid To International Law Firm, Overrules Virtual PE Theory

KC

Khaitan & Co LLP

Nepal Ends DTAA With Mauritius: Legal Implications And Treaty Policy Outlook

NP

Niti Partners and Associates

Seminal Decision Of The Delhi High Court On Constitution Of Service Permanent Establishment

VA

Vaish Associates Advocates

Nepal Issues Longstanding Notification To Seven Tax-Treaty Partners

NP

Niti Partners and Associates

Delhi High Court Upholds Non-taxability Of Fees Paid To International Law Firm, Overrules Virtual PE Theory

In the case of CIT v Clifford Chance Pte Ltd, ITA 353-354/2025, a Division Bench of the High Court of Delhi (High Court) delivered a significant ruling rejecting the theory of virtual presence and held that fees received from India clients by an international law firm is not taxable in India.

KC

Khaitan & Co LLP

Nepal Ends DTAA With Mauritius: Legal Implications And Treaty Policy Outlook

The Government of Nepal has formally terminated the Double Taxation Avoidance Agreement ("DTAA") signed with the Republic of Mauritius on 3 August 1999.

NP

Niti Partners and Associates

Seminal Decision Of The Delhi High Court On Constitution Of Service Permanent Establishment

The Delhi High Court vide recent judgment in the case of Clifford Chance Pte Ltd ("taxpayer") has recorded illuminating findings on the issue of constitution of Service Permanent Establishment ("PE"), which will have significant bearing on assessment of tax positions taken by foreign taxpayers.

VA

Vaish Associates Advocates

Nepal Issues Longstanding Notification To Seven Tax-Treaty Partners

On 12 November 2025 (26 Kartik 2082), the Government of Nepal issued its first formal notification under Section 3(4) of the Income Tax Act 2002 to seven countries with which Nepal has pre-2002 Double Taxation Avoidance Agreements.

NP

Niti Partners and Associates

India Inbound Structuring For Global Groups: Singapore, Netherlands & GIFT City Explained

R & D Law Chambers LLP

An Indirect Transfer In An Offshore Two-tier Structure Is Not Taxable In India – Tax Tribunal Rules In EBay-Flipkart Case

In eBay Singapore Services Private Limited v. DCIT, [TS-1343-ITAT-2025(Mum)], the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) ruled that capital gains arising to a Singapore tax resident...

KC

Khaitan & Co LLP

Separate Notification Required To Invoke MLI

The Delhi Bench of Income-tax Appellate Tribunal (ITAT) in the case of Kosi Aviation Leasing Ltd. (Taxpayer)[1] v. ACIT, has held that single omnibus notification under section 90(1) of the Income-tax Act...

AM

Alvarez & Marsal

Cross-Border Strategies For Founders In SEA And India On Leveraging Convertible Notes

In the dynamic start-up landscapes of Southeast Asia (SEA) and India, convertible notes have become a favoured tool for initial fundraising efforts.

India Commercial

LP

Legitpro Law

The Issue Of Interpretation Of Article 13 (2) Of The Agreement Between Peoples Republic Of China And The Islamic Republic Of Pakistan For Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Evasion Of Taxes.

There are various Chinese companies working in Pakistan. A lot of these companies are working on infrastructure projects involving constructions of Power Projects...

Yousaf Amanat & Associates

PMK 50, PMK 53, And PMK 54 - Redefine Indonesian Crypto Asset Taxation In 2025

AM

Alvarez & Marsal

Key Tax Ruling On Outbound Software Payments: Business Profits vs. Royalties

AM

Alvarez & Marsal

Singapore vs. India: Tax Planning And Business Structuring For Growth

IMC Group

MLI Provisions Unenforceable Without Separate Notification: Mumbai ITAT Rejects Tax Authority's Attempt To Deny DTAA Benefit Using Principal Purpose Test

AM

Alvarez & Marsal

How To Set Up A Branch Office In Malaysia: A Guide For Foreign Companies (2025)

Malaysia Commercial

Aqran Vijandran Advocates & Solicitors

柔佛-新加坡经济特区：要点

Malaysia Commercial

Hsian & Co

Специфика применения соглашений об избежании двойного налогообложения в Кыргызстане

GI

GRATA International

Специфика применения соглашений об избежании двойного налогообложения в Казахстане

GI

GRATA International

Specifics Of Application Of Double Taxation Treaties In Mongolia

GI

GRATA International

Specifics Of Application Of Double Taxation Treaties In Kyrgyzstan

GI

GRATA International

Specifics Of Application Of Double Taxation Treaties In Kazakhstan

GI

GRATA International

India May Have A Case: Evaluating Jane Street's PE Exposure Amid Derivatives Crackdown

BA

BTG Advaya

Investment Vehicles

GA

Globeview Advisors LLP

2025-26 Budget Update: Key Changes To Australian State Taxes - NSW, Qld, WA And ACT

KL

Herbert Smith Freehills Kramer LLP

How President Trump's "One Big Beautiful Bill" Will Impact Businesses In Australia

KG

K&L Gates LLP

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Latest Videos

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Podcast: TaxLand with Fletch and Sarah – Tax Agent Services – the Amended Determination for the Code of Professional Conduct

CG

Cooper Grace Ward

#TaxMantra | AAR To BAR - A Quantum Change

VA

Vaish Associates Advocates

The Drive Towards Transparency: Challenges And Opportunities In International Taxation (Video)

LI

Labuan IBFC Inc

Webinar: India Mauritius Tax Treaty Amended (Capital Gains Tax Benefit Under Mauritius / Singapore Treaties Fall Away): Impact On India Focused Funds And PE/M&A Structures (May 12, 2016) (Video Content)

ND

Nishith Desai Associates

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