Income Tax - Status of a beneficial owner - provisions of Article 12 of...

Income Tax

Status of a beneficial owner - provisions of Article 12 of the DTAA - back-to-back arrangement of passing on the fee received to its holding company - To our minds, once it is held that there was no back-to-back arrangement and the respondent/assessee had dominion and control over the fees received by it and thus entitled to status of a beneficial owner, then, even according to the appellant/revenue, the provisions of Article 12 of the DTAA will kick in. - HC

View Source