Insights

Independent thinking on taxation, policy shifts, and corporate structuring.

Published on Taxmann

Evolution of Share Buyback Taxation in India

A deep dive into how buyback taxation evolved in India and how recent legislative changes reshape corporate capital allocation decisions.

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Published on Taxmann

The 2025 OECD Update on Fixed Place PE

Examining the latest OECD guidance on Permanent Establishment risks in the era of remote work and 'work from home' arrangements.

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Published on Taxmann

DTAA Relief for Fiscally Transparent Entities

Exploring DTAA eligibility for pass-through entities like LLCs and LLPs, and the evolving "tax trail" interpretation by Indian and global courts.

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Published on Taxmann

Deciphering the Fixedness of a Fixed Place PE

A deep dive into the Location, Duration, and Disposal tests required to determine if a foreign enterprise has a taxable presence in India.

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Published on TIOL

Fees for Technical Service - Analysis under Indian Taxation Regime

An analysis of the taxability and contentious issues of FTS within the Income Tax Act, DTAA, and key judicial precedents like the 'Make Available' clause.

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Research Note

Corporate Restructuring under Indian Tax Law

Understanding merger, demerger and slump sale tax implications for modern corporate structures.

Coming Soon

Blogs

Perspectives on emerging tax and regulatory issues.

LinkedIn Article

From Act to Action: Navigating India's DPDP Rules, 2025

India's Digital Personal Data Protection Rules, 2025 have moved the compliance needle from principle to practice. A practical breakdown of obligations for data fiduciaries, vendors, and cross-border platforms under the new framework.

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LinkedIn Article

DRP's Jurisdiction Reaffirmed: Mumbai ITAT Restores Substance Over Procedure

A landmark Mumbai ITAT ruling reinforces that the Dispute Resolution Panel cannot be bypassed on procedural grounds. What this means for taxpayers with pending international transfer-pricing and PE disputes.

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LinkedIn Article

TRC, Form 10F & PAN: A Vendor's Guide to Seamless Cross-Border Tax Compliance

Cross-border payments are a compliance minefield. This step-by-step guide explains how foreign vendors and Indian payers can stay ahead of TDS obligations using Tax Residency Certificates, Form 10F, and PAN requirements.

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