Library Catalogue
Taxation of outbound transaction : in special concern with data's and Vodafone case
Spandana Reddy
Taxation of outbound transaction : in special concern with data's and Vodafone case - BangaloreBangalore NLSIU 2012 - 50 p. ; 25 cm.
TABLE OF CONTENTS I. CHAPTER ONE; Research Methodology; Mode of Citation; Objective of Study; Research Questions; II. CHAPTER TWO; INTRODUCTION Meaning of Inbound" & "Outbound" transactions; III. CHAPTER THREE ; DT AA AGREEMENTS AND ISSUE; I. WHAT IS DOUBLE TAXATION;; II. INDIA AND DOUBLE TAXATION AGREEMENT III. OBJECTIVE OF TAX TREATISE MAIN ISSUES OF DTAA; IV. KEY PRINCIPLE OF DTAA: NON DISCRIMINATION RULE; V. INDIAN POLICY WITH RESPECT TO DOUBLE TAXATION; AVOIDANCE AGREEMENTS; IV. CHAPTER FOUR ; TAXTION OF NON-RESIDENTS; I. FOREIGN INVESTORS; II. IN CASE OF BUSINESS INCOME; V. CHAPTER 5 ; LEGITIMACY OF TAX-PLANNING; I. CORPORATE TAX PLANNING; II. METHOD OF CALCULATING; VI. CHAPTER 6; JUDICIAL APPROACH; I. VODAFONE CASE: FACTS AND DECISION OF THE SUPREME COURT; CONTENTIONS OF VODAFONE; CONTENTIONS OF THE INDIAN TAX AUTHORITIES; II. RAMSAY, AZADI DEBATE; III. CRITICAL ANALYSIS OF SUPREME COURT JUDGEMENT; ON VODAFONE CASE; Sec 9 itself is a look through and it should be given a wide interpretation; Sec 195 applicable as Vodafone had presence in India; IV, SHARE IN THIS CASE AND RELATED ASPECTS; VALUE DERIVED FROM SHARE AMOUNTS TO TRANSFER OF CAPITAL ASSET ; SHARES AS CAPITAL ASSETS; WHAT DOES A SHARE REPRESENTS; V. STRUCTURING BUSINESS FOR TAX PLANNING; AZADI BACHAO CASE; DECIDING FACTOR IN NON RESIDENT; ONLY PRETENCE AND FACAD; KHARW AR CASE; UNRAVEL IF COMPANY CONCEAL; TAX PLANNING; TAXATION OF NON-RESIDENTS; PHYSICAL PRESENCE AND SOURCE RULE; VI. . UK CASES; EXTRA TERRITORIALITY; Clark (Inspector of Taxes) Oceanic Contractors Inc; Agassi v. Robinson; CHAPTER 7; IMPACT OF DTC ON OUTBOUND TRANSACTIONS; I. INDIRECT TRANSFERS; II. RESIDENCY RULE FOR FOREIGN COMPANIES; CHAPTER 8; CONCLUSION; BIBLIOGRAPHY.
Taxation of outbound transaction : in special concern with data's and Vodafone case - BangaloreBangalore NLSIU 2012 - 50 p. ; 25 cm.
TABLE OF CONTENTS I. CHAPTER ONE; Research Methodology; Mode of Citation; Objective of Study; Research Questions; II. CHAPTER TWO; INTRODUCTION Meaning of Inbound" & "Outbound" transactions; III. CHAPTER THREE ; DT AA AGREEMENTS AND ISSUE; I. WHAT IS DOUBLE TAXATION;; II. INDIA AND DOUBLE TAXATION AGREEMENT III. OBJECTIVE OF TAX TREATISE MAIN ISSUES OF DTAA; IV. KEY PRINCIPLE OF DTAA: NON DISCRIMINATION RULE; V. INDIAN POLICY WITH RESPECT TO DOUBLE TAXATION; AVOIDANCE AGREEMENTS; IV. CHAPTER FOUR ; TAXTION OF NON-RESIDENTS; I. FOREIGN INVESTORS; II. IN CASE OF BUSINESS INCOME; V. CHAPTER 5 ; LEGITIMACY OF TAX-PLANNING; I. CORPORATE TAX PLANNING; II. METHOD OF CALCULATING; VI. CHAPTER 6; JUDICIAL APPROACH; I. VODAFONE CASE: FACTS AND DECISION OF THE SUPREME COURT; CONTENTIONS OF VODAFONE; CONTENTIONS OF THE INDIAN TAX AUTHORITIES; II. RAMSAY, AZADI DEBATE; III. CRITICAL ANALYSIS OF SUPREME COURT JUDGEMENT; ON VODAFONE CASE; Sec 9 itself is a look through and it should be given a wide interpretation; Sec 195 applicable as Vodafone had presence in India; IV, SHARE IN THIS CASE AND RELATED ASPECTS; VALUE DERIVED FROM SHARE AMOUNTS TO TRANSFER OF CAPITAL ASSET ; SHARES AS CAPITAL ASSETS; WHAT DOES A SHARE REPRESENTS; V. STRUCTURING BUSINESS FOR TAX PLANNING; AZADI BACHAO CASE; DECIDING FACTOR IN NON RESIDENT; ONLY PRETENCE AND FACAD; KHARW AR CASE; UNRAVEL IF COMPANY CONCEAL; TAX PLANNING; TAXATION OF NON-RESIDENTS; PHYSICAL PRESENCE AND SOURCE RULE; VI. . UK CASES; EXTRA TERRITORIALITY; Clark (Inspector of Taxes) Oceanic Contractors Inc; Agassi v. Robinson; CHAPTER 7; IMPACT OF DTC ON OUTBOUND TRANSACTIONS; I. INDIRECT TRANSFERS; II. RESIDENCY RULE FOR FOREIGN COMPANIES; CHAPTER 8; CONCLUSION; BIBLIOGRAPHY.