Satyam Computer Services Limited v Commissioner of Taxation, [2018] FCAFC 172

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Summaries

Summary Under

a sourcing rule in the Australia-India Treaty imposed tax on a deemed royalty received by an Indian company

In Tech Mahindra, computer services provided by employees of the taxpayer located in India to Australian companies were found to be royalties...

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Summary Under

wording of Treaty sourcing rule had the effect of expanding scope of domestic provision

The Indian taxpayer (Satyam) argued unsuccessfully before the Full Federal Court of Australia “that tax treaties are, and can only be,...

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