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., 2009 DTC 5721, 2009 FCA 57-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 The taxpayer paid dividends to its shareholder, ("Prévost Holding"), a Netherlands holding company which, in turn, paid dividends in substantially the same amount to its two corporate shareholders, a Swedish and UK corporation. ...

Income Tax Convention (a claim which, in this case, was unsupported by the evidence). ...

Valentine Maritime (Mauritius) Ltd. (2010), 38 DTR 117 (Mumbai ITAT)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 projects not interconnected The taxpayer ("Valentine") was a Mauritius company which carried on several construction projects in India, in connection with which it provided construction services in India for various customers. ...

The Queen, 2006 DTC 2705, 2006 TCC 246-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 The taxpayer provided a fully-crewed vessel under a charter party to a Canadian resident company for the purpose of transporting pipe and other materials from Nova Scotia to two ships of the Canadian company laying pipe off the coast of Nova Scotia within the Sable Island offshore area. ...

Morgan Stanley (2007), 9 ITLR 1124 (India SC)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "seconded" employees remained employees of non-resident so that services provided The taxpayer ("MSCo") sent its employees to its subsidiary in India ("MSAS") to oversee MSAS's staff in monitoring the outsourcing activities at MSAS and also sent employees on secondment (or "deputation") to MSAS. ...

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 documentary demands made by HMRC pursuant to Art. 27 on UK companies being investigated by Australia were valid The Australian Tax Office, which suspected that a UK accounting firm was providing nominee directors and shareholders to UK-incorporated companies to make them look like they were factually resident outside Australia, made a request to the UK Revenue (HMRC) pursuant to Art. 27 of the UK-Australia Treaty (somewhat similar to Art. 24 of the Canada-U.K. ...

(C)-7416/2012 (Delhi High Court)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 charges for use of the installer’s own equipment were not royalties for equipment use The taxpayer was a Singapore company which installed a marine crude oil receiving facility over a 41-day period for Indian Oil Corporation Ltd (“IOCL‟) at a contract price of U.S.$18.6 million. ...

The Queen, 2016 TCC 283 (Informal Procedure)-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 application of Art. 24 of Canada-U.S. ...

Canada, 2017 FCA 3-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 a Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income At issue was whether Art. ...

Moller Maersk, Civil Appeal No. 2960 of 2017 (Supreme Court Of India, Civil Appellate Jurisdiction)-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 computer tracking-system charges of a Danish company to agents in India were profits of its international shipping business A Danish international shipping company (“Maersk”) charged local agents in India, who booked and tracked cargo, for their pro rata share of the costs of a Maersk computer and telecommunication system that was key to these functions. ...