Tax
Apr. 16, 2013
India seeks to tax offshore transactions involving Indian assets
The harsh results of the new law, especially its retroactive application, have made the situation unpalatable to non-Indian multinationals. By Robin Chesler and Naomita Yadav
As many are aware, in the headline-making Vodafone International Holdings Ltd v. Union of India (2012), the Supreme Court of India, ruling in favor of the taxpayer, held that Section 9(1)(i) of the Indian Income Tax Act did not cover an indirect stock transfer (i.e., Vodafone's purchase of the shares of a Cayman company that indirectly owned an Indian company with assets located in India), contra...
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