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March 2010
Tax Edge Special - Royal Bank of Canada
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Contents

The AAR rules that income arising to an FII from derivative transactions is ‘Business income’ and not liable to tax in India in the absence of permanent establishment (‘PE’) in India

Tax Edge Special - Obligation to withhold tax arises only if the income is liable to tax in India
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Tax Edge Special - Advance Ruling on capital gains on transfer of shares by a Mauritian company
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Tax Edge Special - AAR holds no gains arise on conversion of partnership firm to company
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Tax Edge Special - AAR ruling on reimbursement of R&D expenses under Cost Contribution Arrangement
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Tax Edge Special - AAR rules on beneficial ownership for treaty purposes
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Tax Edge Special - AAR holds transfer of shares without consideration is not liable to tax
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