The document discusses several proposed amendments to international taxation in India:
1. Indirect transfer of shares of Indian companies would be taxable in India, nullifying a Supreme Court judgment. This could impact overseas acquisitions and intra-group restructurings.
2. A general anti-avoidance rule would be introduced to tax arrangements based on their commercial substance over their legal form. This increases uncertainty around tax planning.
3. The scope of royalties would be expanded for tax purposes to include computer software licensing, not in line with international principles.
Negotiating Reverse and Forward Triangular Mergers Roger Royse
Overview
(1) What is a forward/reverse triangular merger?
(2) Legal steps to follow
(3) Anti-assignment clauses
(4) Benefits of triangular mergers
(5) Forward vs. reverse
Analysis of "Fees for Technical Services" and its TaxabilityDVSResearchFoundatio
Key Takeaways
Analysis of the definition under the Income tax act and taxability
Implications under DTAA
Understanding of make available clause and most favoured nation clause
Taxability when no FTS clause in DTAA
Relevant illustrations and judicial precedents
This presentation enumerates the practical aspects of merger, demerger and reduction of capital and the strategies involved therein. It also highlights certain key issues involved in corporate restructuring.
This presentation enumerates the practical aspects of merger, demerger and reduction of capital and the strategies involved therein. It also highlights certain key issues involved in corporate restructuring.
Presentation given to the National Association of Stock Plan Professionals' Chicago Chapter on the Executive Compensation and Corporate Governance provisions of the Dodd-Frank Act, which was signed into law by President Obama on July 21, 2010.
This presentation enumerates the practical aspects of merger, demerger and reduction of capital and the strategies involved therein. It also highlights certain key issues involved in corporate restructuring.
The Italian Supreme Court clarified that an investment contract that awards the investor a put option enabling him to sell back the shares he has previously purchased at a striking price equal to the initial investment is lawful where the real purpose of the transaction is to raise capital for the issuer of the shares.
This is a brief explanation of some of the te
rms you may come across in company insolvency
proceedings. Please note that this glossary is for ge
neral guidance only. Many of the terms have a
specific technical meaning in certain c
ontexts that may not be covered here.
Negotiating Reverse and Forward Triangular Mergers Roger Royse
Overview
(1) What is a forward/reverse triangular merger?
(2) Legal steps to follow
(3) Anti-assignment clauses
(4) Benefits of triangular mergers
(5) Forward vs. reverse
Analysis of "Fees for Technical Services" and its TaxabilityDVSResearchFoundatio
Key Takeaways
Analysis of the definition under the Income tax act and taxability
Implications under DTAA
Understanding of make available clause and most favoured nation clause
Taxability when no FTS clause in DTAA
Relevant illustrations and judicial precedents
This presentation enumerates the practical aspects of merger, demerger and reduction of capital and the strategies involved therein. It also highlights certain key issues involved in corporate restructuring.
This presentation enumerates the practical aspects of merger, demerger and reduction of capital and the strategies involved therein. It also highlights certain key issues involved in corporate restructuring.
Presentation given to the National Association of Stock Plan Professionals' Chicago Chapter on the Executive Compensation and Corporate Governance provisions of the Dodd-Frank Act, which was signed into law by President Obama on July 21, 2010.
This presentation enumerates the practical aspects of merger, demerger and reduction of capital and the strategies involved therein. It also highlights certain key issues involved in corporate restructuring.
The Italian Supreme Court clarified that an investment contract that awards the investor a put option enabling him to sell back the shares he has previously purchased at a striking price equal to the initial investment is lawful where the real purpose of the transaction is to raise capital for the issuer of the shares.
This is a brief explanation of some of the te
rms you may come across in company insolvency
proceedings. Please note that this glossary is for ge
neral guidance only. Many of the terms have a
specific technical meaning in certain c
ontexts that may not be covered here.
Joint Venture & Strategic Alliance- hu consultancyHU Consultancy
A Joint Venture (JV) is a business arrangement in which two or more parties agree to pool their resources and expertise to achieve a particular goal. The risks and rewards of the enterprise are also shared.
Joint Venture & Strategic Alliance- hu consultancyHU Consultancy
A Joint Venture (JV) is a business arrangement in which two or more parties agree to pool their resources and expertise to achieve a particular goal. The risks and rewards of the enterprise are also shared.
For Joint Venture & Strategic Alliance contact us at (020) 2442 – 0209. Visit http://huconsultancy.com/
The controversy of Dividend distribution tax.pptxtaxguruedu
Dividend distribution tax is one of the most controversial topics in the income tax area, and it has welcomed many judicial decisions. DDT is a tax levied on dividends distributed by companies out of their profits amongst their shareholders.1
Inbound investment re-organisation - Indian Tax and regulatory issuesAjay Kumar
Foreign companies keep on reorganizing their investments. Under the Indian tax laws, transfer of shares of an Indian company can trigger taxable gains even when the transfer is within the same group. This is subject to certain exemptions.
1. Elemental Economics - Introduction to mining.pdfNeal Brewster
After this first you should: Understand the nature of mining; have an awareness of the industry’s boundaries, corporate structure and size; appreciation the complex motivations and objectives of the industries’ various participants; know how mineral reserves are defined and estimated, and how they evolve over time.
This presentation poster infographic delves into the multifaceted impacts of globalization through the lens of Nike, a prominent global brand. It explores how globalization has reshaped Nike's supply chain, marketing strategies, and cultural influence worldwide, examining both the benefits and challenges associated with its global expansion.
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Rubber Materials Nike
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Genuine Leather Nike
Synthetic Leather Nike
Cotton in Nike Apparel
Nike Shops Worldwide
Nike Manufacturing Countries
Cold Cement Assembly Nike
3D Printing Nike Shoes
Nike Product Development
Nike Marketing Strategies
Nike Customer Feedback
Nike Distribution Centers
Automation in Nike Manufacturing
Nike Consumer Direct Acceleration
Nike Logistics and Transport
Yes of course, you can easily start mining pi network coin today and sell to legit pi vendors in the United States.
Here the what'sapp contact of my personal vendor.
+12349014282
#pi network #pi coins #legit #passive income
#US
Seminar: Gender Board Diversity through Ownership NetworksGRAPE
Seminar on gender diversity spillovers through ownership networks at FAME|GRAPE. Presenting novel research. Studies in economics and management using econometrics methods.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
2. Elemental Economics - Mineral demand.pdfNeal Brewster
After this second you should be able to: Explain the main determinants of demand for any mineral product, and their relative importance; recognise and explain how demand for any product is likely to change with economic activity; recognise and explain the roles of technology and relative prices in influencing demand; be able to explain the differences between the rates of growth of demand for different products.
how to sell pi coins in South Korea profitably.DOT TECH
Yes. You can sell your pi network coins in South Korea or any other country, by finding a verified pi merchant
What is a verified pi merchant?
Since pi network is not launched yet on any exchange, the only way you can sell pi coins is by selling to a verified pi merchant, and this is because pi network is not launched yet on any exchange and no pre-sale or ico offerings Is done on pi.
Since there is no pre-sale, the only way exchanges can get pi is by buying from miners. So a pi merchant facilitates these transactions by acting as a bridge for both transactions.
How can i find a pi vendor/merchant?
Well for those who haven't traded with a pi merchant or who don't already have one. I will leave the what'sapp number of my personal pi merchant who i trade pi with.
Message: +12349014282 VIA Whatsapp.
#pi #sell #nigeria #pinetwork #picoins #sellpi #Nigerian #tradepi #pinetworkcoins #sellmypi
Abhay Bhutada Leads Poonawalla Fincorp To Record Low NPA And Unprecedented Gr...Vighnesh Shashtri
Under the leadership of Abhay Bhutada, Poonawalla Fincorp has achieved record-low Non-Performing Assets (NPA) and witnessed unprecedented growth. Bhutada's strategic vision and effective management have significantly enhanced the company's financial health, showcasing a robust performance in the financial sector. This achievement underscores the company's resilience and ability to thrive in a competitive market, setting a new benchmark for operational excellence in the industry.
STREETONOMICS: Exploring the Uncharted Territories of Informal Markets throug...sameer shah
Delve into the world of STREETONOMICS, where a team of 7 enthusiasts embarks on a journey to understand unorganized markets. By engaging with a coffee street vendor and crafting questionnaires, this project uncovers valuable insights into consumer behavior and market dynamics in informal settings."