04825nam 22006975 450 991036657050332120200629122835.081-322-3670-X10.1007/978-81-322-3670-2(CKB)4100000009844959(MiAaPQ)EBC5979096(DE-He213)978-81-322-3670-2(PPN)248602934(EXLCZ)99410000000984495920191116d2020 u| 0engurcnu||||||||txtrdacontentcrdamediacrrdacarrierInternational Taxation[electronic resource] The Indian Perspective /by Nigam Nuggehalli1st ed. 2020.New Delhi :Springer India :Imprint: Springer,2020.1 online resource (xi, 112 pages) illustrationsSpringerBriefs in Law,2192-855X81-322-3668-8 Includes bibliographical references.Introduction: Contracts and tax law -- 1. Indian tax legislation and international tax treaties -- 2. Judiciary, contracts and tax -- 3. Business income and permanent establishment -- 4. International corporate acquisitions and capital gains -- 5. Taxation of cross-border royalty payments -- 6. Taxation of cross-border technical service payments -- 7. Transfer pricing -- 8. General anti-avoidance rules -- 9. Indian international taxation and the OECD initiative on BEPS (Base Erosion and Profit Shifting) -- 10. Conclusion.This book covers all major topics in international tax law, ranging from permanent establishments and capital gains to the taxation of royalties and technical services, transfer pricing, and General Anti-Avoidance Legislation. It also highlights the Indian “story” of status vs. contract by examining four areas of controversy: permanent establishments, FTS (Fees for Technical Services) & Royalty, capital gains, and transfer pricing. The book approaches the subject of international taxation from two opposing yet related perspectives. One is the tax planning perspective, which involves contracts entered into by individuals and companies; the other is that of state regulation through increasingly complex legislation. The area of permanent establishments demonstrates the dominance of contracts over status, at least with respect to Indian tax law. However, some recent judicial decisions in this area demonstrate the susceptibility of contracts to status-related arguments. The areas of FTS & Royalty as well as those of capital gains and transfer pricing demonstrate the Indian government’s attempts to establish, through legislation, the dominance of status over contracts. Whereas traditional textbooks on international tax law focus on the legal technicalities of tax legislation, this book provides tax scholars and lawyers with an understanding of tax planning and tax legislation side by side in each chapter, specifying the respective kind of actual or anticipated tax planning activity that in turn prompted a legislative response. As such, it offers readers a contextual and practical introduction to the complexities of international tax law, as well as an in-depth analysis of the latest debates and controversies in this area.SpringerBriefs in Law,2192-855XPrivate international lawConflict of lawsTax accountingTax lawsInternational lawTradePublic financePrivate International Law, International & Foreign Law, Comparative Law https://scigraph.springernature.com/ontologies/product-market-codes/R14002Business Taxation/Tax Lawhttps://scigraph.springernature.com/ontologies/product-market-codes/511010International Economic Law, Trade Lawhttps://scigraph.springernature.com/ontologies/product-market-codes/R19050Financial Law/Fiscal Lawhttps://scigraph.springernature.com/ontologies/product-market-codes/R17044Private international law.Conflict of laws.Tax accounting.Tax laws.International law.Trade.Public finance.Private International Law, International & Foreign Law, Comparative Law .Business Taxation/Tax Law.International Economic Law, Trade Law.Financial Law/Fiscal Law.341.484Nuggehalli Nigamauthttp://id.loc.gov/vocabulary/relators/aut882879MiAaPQMiAaPQMiAaPQBOOK9910366570503321International Taxation1972317UNINA