INTL

Cross-border secondment arrangements have traditionally been structured by multinational groups as internal deployment arrangements rather than as taxable service transactions. Indian subsidiaries and...

1. The Changing Treaty LandscapeIndia’s approach to tax treaty claims has moved into a more uncertain and fact-sensitive phase after the Supreme Court’s ruling in Authority of Advance Rulings (Income...

1. The problem: one transparent firm, many treaty residencesConsider a United Kingdom limited liability partnership carrying on a global professional services practice. It is fiscally transparent in t...

1. Why secondment arrangements have become high-risk in IndiaEmployee secondment within multinational groups is no longer treated by Indian tax authorities as a routine internal human-resource movemen...

1. Why secondment arrangements now need board-level attentionEmployee secondment within multinational groups is no longer viewed by Indian tax authorities as a routine internal HR movement. In many ca...