Chamber of Tax Consultants

International Tax Journal

Editorial

From the President

Permanent Establishment under India-Australia Treaty and under India-Singapore Treaty in the case of Satyam Computers and Mastercard

Residence and effective management under Canada- Netherlands Treaty and concept of ‘excluded property’ under Canada- Luxembourg Treaty in the case of Backx and Alta Energy

Treaty Entitlement to Fiscally Transparent Entities in the case of RCF IV and V, Australia

Permanent establishments and intangible fixed assets in the case of Bloomberg, UK

Royalties under the India-Ireland Tax Treaty in the case of Google, India

Principal purpose test under US – Switzerland Treaty and Foreign Tax Credit in New Zealand in the case of Starr International Co and Ms Lin

Issues relating to Country of habitual abode in the case of Mr. X, South Africa, Lenenberger, USA and Wentworth, USA

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