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International Taxation

The Indian Perspective

  • Nigam Nuggehalli
Book

Part of the SpringerBriefs in Law book series (BRIEFSLAW)

Table of contents

  1. Front Matter
    Pages i-xi
  2. Nigam Nuggehalli
    Pages 1-3
  3. Nigam Nuggehalli
    Pages 17-27
  4. Nigam Nuggehalli
    Pages 29-46
  5. Nigam Nuggehalli
    Pages 47-63
  6. Nigam Nuggehalli
    Pages 65-73
  7. Nigam Nuggehalli
    Pages 75-82
  8. Nigam Nuggehalli
    Pages 83-94
  9. Back Matter
    Pages 109-112

About this book

Introduction

This book covers all major topics in international tax law, ranging from permanent establishments and capital gains to the taxation of royalties and technical services, transfer pricing, and General Anti-Avoidance Legislation. It also highlights the Indian “story” of status vs. contract by examining four areas of controversy: permanent establishments, FTS (Fees for Technical Services) & Royalty, capital gains, and transfer pricing. The book approaches the subject of international taxation from two opposing yet related perspectives. One is the tax planning perspective, which involves contracts entered into by individuals and companies; the other is that of state regulation through increasingly complex legislation.

The area of permanent establishments demonstrates the dominance of contracts over status, at least with respect to Indian tax law. However, some recent judicial decisions in this area demonstrate the susceptibility of contracts to status-related arguments. The areas of FTS & Royalty as well as those of capital gains and transfer pricing demonstrate the Indian government’s attempts to establish, through legislation, the dominance of status over contracts.

Whereas traditional textbooks on international tax law focus on the legal technicalities of tax legislation, this book provides tax scholars and lawyers with an understanding of tax planning and tax legislation side by side in each chapter, specifying the respective kind of actual or anticipated tax planning activity that in turn prompted a legislative response. As such, it offers readers a contextual and practical introduction to the complexities of international tax law, as well as an in-depth analysis of the latest debates and controversies in this area.

Keywords

Base Erosion and Profit Shifting Contracts and Tax Law Income Tax India India International Tax Tax Avoidance Tax Planning Transfer Pricing Vodafone Tax

Authors and affiliations

  • Nigam Nuggehalli
    • 1
  1. 1.School of Law, BML Munjal UniversityGurugramIndia

Bibliographic information

  • DOI https://doi.org/10.1007/978-81-322-3670-2
  • Copyright Information The Author(s), under exclusive licence to Springer Nature India Private Limited 2020
  • Publisher Name Springer, New Delhi
  • eBook Packages Law and Criminology
  • Print ISBN 978-81-322-3668-9
  • Online ISBN 978-81-322-3670-2
  • Series Print ISSN 2192-855X
  • Series Online ISSN 2192-8568
  • Buy this book on publisher's site