Social media profiles used as evidence of PE

ConstantinosInternational Tax0 Comments

Recently, the Delhi Bench of the Income Tax Appellate Tribunal (the tribunal) in the case of GE Energy Parts Inc v ADIT (ITA No. 671/Del/2011) held that the LinkedIn profiles of the employees of the GE group submitted by the tax authorities were admissible as evidence in determining the existence of a PE in India. The tribunal’s view was that … Read More

New Cyprus-India Double Tax Treaty

ConstantinosCyprus tax, DTT's0 Comments

Notification as a non-cooperative jurisdiction In a previous post, on 01.11.2013, the Indian Ministry of Finance issued a notification classifying Cyprus as a non-cooperative jurisdiction for tax matters. The decision has adversely affected investors using Cyprus companies for inbound or outbound Indian investments. In a summary, payments from India to Cyprus have attracted  a 30% Indian withholding tax, application of the tough … Read More