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Public Lecture Meeting on Recent Development in International Taxation

PUBLIC LECTURE MEETING ON RECENT DEVELOPMENT IN INTERNATIONAL TAXATION

INTERNATIONAL TAXATION COMMITTEE

Chairman :

Rajesh P. Shah

Co-Chairman : Rajesh L. Shah
Vice-Chairman : Kartik Badiani
Convenors : Isha Sekhri, Shreyas Shah, Harshal Bhuta, Rakesh Upadhyaya
Advisor : Dilip J. Thakkar

A Permanent Establishment of a foreign enterprise in India is the fundamental criterion under the tax treaties for taxation of foreign company’s business income in India. Some of the recent decisions have given a new dimension to the concept of PE under the Treaty. Notable amongst them are (1) Supreme Court in Formula One World Championship Ltd.’s case wherein the Hon’ble Apex Court has laid more emphasis on the ‘control’ over the place of business as against place being at the ‘disposal’ of the foreign enterprise; and (2) In the present technology era where the services are provided through technology from the home country via email, internet, video conference, etc. Bengaluru Tribunal in ABB FZE LLC’s case in the context of Service PE has held that for determination of service PE provision of services in a host country to also include services rendered from home country of the foreign company and physical presence of employees in India is not the sole criteria for determining existence of the Service PE. With few such judgements and GAAR coming in, tax planning is certainly going to be a challenging affair. Further Indian judiciary approach is worth seeing as we go along.

Our extremely learned faculty CA Himanshu Parekh, presently Head – Media & Entertainment Tax practice at KPMG, will take us through some of the recent development in International Taxation. Mr. Parekh has over two decades of professional experience on a variety of tax and regulatory matters. He has extensive experience on cross-border tax issues and investment structuring, both, inbound and outbound.

Details of the meeting are as under:

Day & Date

:

Thursday, October 5, 2017 

Time : 5.30 p.m. to 6.00 p.m. (Fellowship over Tea)
6.00 p.m. to 8.00 p.m. (Meeting)
Speaker : CA Himanshu Parekh
Venue : Babubhai Chinai Committee Room, 2nd Floor, IMC, Churchgate, Mumbai-400 020

All are cordially invited to take benefit of this unique lecture meeting

Event Properties

Event date: 05-Oct-2017 5:30 pm
Event End Date: 05-Oct-2017 8:00 pm
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