The French Administrative Supreme Court issued a judgment in February that clarifies the assessment of company residence for access to double tax treaty (DTT) benefits, as Nicolas Duboille and Clément Riccio of Sumerson explain.
The French Administrative Supreme Court issued a judgment in February that clarifies the assessment of company residence for access to double tax treaty (DTT) benefits, as Nicolas Duboille and Clément Riccio of Sumerson explain.
U K , U S Reach Competent Authority Agreement On mondaq.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from mondaq.com Daily Mail and Mail on Sunday newspapers.
Monday, March 8, 2021
SC” or “
Court”) while ruling in favour of the taxpayers has put to rest the controversy on characterization of payments made by Indian residents for use / resale of computer software (“
Judgement”).
1 The SC held that the amounts paid by resident Indian end-users / distributors to non-resident computer software manufacturers / suppliers, as consideration for the resale / use of the computer software through End-user Licensing Agreements (“
EULAs”) / distribution agreements, is not the payment of royalty for the use of copyright in the computer software, and that the same does not give rise to any income taxable in India. Accordingly, the SC concluded that the person referred to in section 195 of the Income-tax Act, 1961 (“
Highlights
Expatriation has increased significantly in 2020. The latest
U.S. Department of the Treasury Report reflects that a record 6,047
individuals expatriated during the first three quarters of 2020. In
addition, 834,000 green card holders became U.S.
citizens in FY 2019, which reflects an 11-year high.
Why are so many individuals expatriating? Perhaps it is because
we live in chaotic times, ranging from the pandemic to the
contentious presidential election and transition, among other
reasons. Further, U.S. taxpayers increasingly are considering
moving a portion of their financial portfolios offshore for
diversification and to facilitate global trading.
The increase in expatriation also has caught the attention of