Here is another episode of LKS’ all Law., where Mr. Devesh Aswal and Ms. Neha Jain discuss the topic “Cross-Border Share Sale – Eligibility for Tax Treaty Benefit”. The benefit under the tax treaty is subject to provisions of General Anti Avoidance Rules (GAAR) enacted under the domestic law and Principal purpose test (PPT) embedded in tax treaties. Under both GAAR and PPT, the benefit of tax treaties should be available only for transactions having commercial substance. Though both GAAR...
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Here is another episode of LKS’ all Law., where Mr. Devesh Aswal and Ms. Neha Jain discuss the topic “Cross-Border Share Sale – Eligibility for Tax Treaty Benefit”. The benefit under the tax treaty is subject to provisions of General Anti Avoidance Rules (GAAR) enacted under the domestic law and Principal purpose test (PPT) embedded in tax treaties. Under both GAAR and PPT, the benefit of tax treaties should be available only for transactions having commercial substance. Though both GAAR...
While the inclusion of interest amounts in ‘financial debt’, for the purposes of the Insolvency and Bankruptcy Code, 2016 (‘IBC’), is clearly provided for in the IBC, the interest component in the case of operational debt has always been a point of contention.Definition of the term ‘financial debt’under Section 5(8) of the IBC expressly includes the term ‘interest’ to be a part of the debt that can form a part of the claim against the corporate debtor. However, the definition of the term ‘ope...
all Law.
Here is another episode of LKS’ all Law., where Mr. Devesh Aswal and Ms. Neha Jain discuss the topic “Cross-Border Share Sale – Eligibility for Tax Treaty Benefit”. The benefit under the tax treaty is subject to provisions of General Anti Avoidance Rules (GAAR) enacted under the domestic law and Principal purpose test (PPT) embedded in tax treaties. Under both GAAR and PPT, the benefit of tax treaties should be available only for transactions having commercial substance. Though both GAAR...
