LIN V COMMISSIONER OF INLAND REVENUE – IN THE COURT OF APPEAL OF NEW ZEALAND In this case, the Court of Appeal had to deal with whether Ms Lin was entitled to a credit against income tax liability in New Zealand arising due to CFC companies in China for tax spared by China on income […]
ANALYSIS OF DECISIONS IN THE CASE OF STARR INTERNATIONAL COMPANY, INC V USA
STARR INTERNATIONAL COMPANY, INC., v. UNITED STATES OF AMERICA by UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA The District Court of Columbia dealt with the issue whether Starr International Company Inc (hereinafter referred as “Starr” for brevity) is eligible for lower tax rate on dividends it receives from US sources applying the United […]
SC DECISION IN THE CASE OF DIT V SAMSUNG HEAVY INDUSTRIES CO LTD 117 TAXMANN.COM 870 (SC) – ANALYSIS AND LEARNINGS
Background This decision ((2020) 7 SCC 347) of the Honourable Supreme Court deals with the question as to the taxability of income attributable to a “permanent establishment” set up in a fixed place in India under the India – Republic of Korea (“DTAA”). On 28.02.2006, the Oil and Natural Gas Company (“ONGC”) awarded a “turnkey” […]