Description
CCH India The Law And Practice Of Tax Treaties: An Indian Perspective by Nilesh Modi
The importance of tax treaty interpretation is at its peak in India. In recent years, the pace of the Indian jurisprudence on tax treaties has been astounding. Foreign decisions and overseas revenue rulings are being increasingly considered in India while interpreting tax treaties. The second and updated edition explains the Model Conventions with reference to, inter alia, the Indian decisions, CBDT Circulars, overseas jurisprudence, Australian Taxation Office (ATO) rulings, and Technical Explanations to the Indian treaties with US and Australia. The book provides a reference to the Model Commentaries as well as to the OECD Reports and analyses whether the UN/OECD view is in consonance with or departs from the Indian/overseas jurisprudence.
Key Features:-
- Separate analysis of the each of the 30 Articles in the UN Model
- 1,350 Indian decisions, 850 foreign judgments
- From 40 countries and 100 ATO rulings
- Detailed chapter on principles for “Interpretation of Tax Treaties”
- Chapter on taxability of “Fees for Technical Services” and “E-Commerce”
- Analysis under easy-to-find headings and sub-headings