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The Central Board of Direct Taxes (CBDT) released its 7th Annual Report on the Advance Pricing Agreement (APA) Programme for FY 2024–2025, marking a record year in terms of agreements signed, bilateral cooperation, and tax certainty.

In this issue, we highlight key updates on cross-border investment vehicles and their role in facilitating investments into and out of India.

The Ministry of Finance, Government of India, has issued a Press Release on 10 May 2016 that marks a watershed moment in India's quest with tax avoidance and the ‘substance over form' debate.

The Hon'ble Supreme Court of India (Apex Court) has recently pronounced a landmark ruling[ᶦ] on treaty interpretation with a specific reference to Most Favored Nation...

The India–United Kingdom Comprehensive Economic and Trade Agreement (“India‑UK CETA”) will enter into force with effect from 15 July 2026. Consequently, the Customs Tariff...

The long-standing tax controversy surrounding ‘off-the-shelf software' or ‘shrink-wrapped software' or ‘standard software' has finally come to rest with the Hon'ble Supreme Court's verdict on 2 March 2021.

India and Hong Kong have recently signed a long awaited tax treaty which will significantly impact MNCs, funds and entrepreneurs with respect to investments and transactions between the two countries.

Per the extant India-Mauritius tax treaty ("Tax Treaty"), capital gains on sale of Indian company shares (acquired prior to 1 April 2017) and sale of derivatives...

Recently, the Central Board of Direct Taxes ("CBDT") released a circular ("Circular") providing clarifications on implementation of General Anti-Avoidance Rules ("GAAR").

Post the economic reforms of 1991, the Indian economy was opened up to integrate with the global market, which involved cross border movement of technology, personnel, capital, equipment etc.

This case deals with a Cyprus taxpayer which was earning interest income from India.

There can be no straight jacket formula to determine what is meant by "provision of service," which may include where services are i) provided; ii) rendered; or iii) utilized.

As discussed in our previous update, India and Mauritius have signed a protocol amending the India-Mauritius tax treaty.

On 20th January 2012, the Supreme Court of India vide its judgment and order in Civil Appeal No.733/2012

Revenues earned by MNCs from India often remain under the lens of the Indian taxation authorities for examination of constitution of Permanent Establishment...

As per recent press articles, the Indian and French governments are in the closing stages of finalizing the revised Double Taxation Avoidance Agreement (DTAA or Tax Treaty).

Recently, the AA in the case of GEA Refrigeration Technologies GmbH, In re, ruled that the income derived by German shareholders from the sale of equity shares of a German company...