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Tech Mahindra Ltd v. Commissioner of Taxation

Australia.  22 September 2016 .

Published online by Cambridge University Press:  01 January 2021

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Abstract

Treaties — Interpretation — Application — Agreement between Government of Australia and Government of Republic of India for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income, 1991 — Operation of “business profits rule” — Article 7 — Operation of “royalties provision” — Article 12 — Principles of interpretation — Vienna Convention on the Law of Treaties, 1969, Article 31 — Whether source State having right to tax royalties under Article 7 or 12 — The law of Australia

Keywords

Type
Case Report
Copyright
© Cambridge University Press 2019

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