The Resource ABN Amro Bank NV v Assistant Director of Income Tax International Taxation-I, Kolkata : Assistant Director of Income Tax International Taxation-I, Kolkata v Bank of Tokyo Mitsubishi Ltd : ITA nos 694 and 695/Kol/2002 (assessment years 1997-98 and 1996-99) and ITA no 899/Kol/2002 (assessment year 1992-93)

ABN Amro Bank NV v Assistant Director of Income Tax International Taxation-I, Kolkata : Assistant Director of Income Tax International Taxation-I, Kolkata v Bank of Tokyo Mitsubishi Ltd : ITA nos 694 and 695/Kol/2002 (assessment years 1997-98 and 1996-99) and ITA no 899/Kol/2002 (assessment year 1992-93)

Label
ABN Amro Bank NV v Assistant Director of Income Tax International Taxation-I, Kolkata : Assistant Director of Income Tax International Taxation-I, Kolkata v Bank of Tokyo Mitsubishi Ltd : ITA nos 694 and 695/Kol/2002 (assessment years 1997-98 and 1996-99) and ITA no 899/Kol/2002 (assessment year 1992-93)
Title
ABN Amro Bank NV v Assistant Director of Income Tax International Taxation-I, Kolkata : Assistant Director of Income Tax International Taxation-I, Kolkata v Bank of Tokyo Mitsubishi Ltd : ITA nos 694 and 695/Kol/2002 (assessment years 1997-98 and 1996-99) and ITA no 899/Kol/2002 (assessment year 1992-93)
Subject
Language
eng
Summary
Judgment by the Income Tax Appellate Tribunal dated 22 August 2005. The cases concern the deduction of interest by branches on loans from the head office. The tax authorities disallowed the deduction on grounds that, under Indian domestic tax law, interest paid to a non-resident could only be deducted if tax had been withheld on the payment of the interest. The first issue was whether the interest should be deducted in determining the profits attributable to the permanent establishment. The second issue was whether the branch was required to withhold tax on the payment of notional interest to its head office
Citation source
In: International tax law reports. - London. - Vol. 8 (2006),
Language note
English
http://library.link/vocab/subjectName
  • case law
  • PE
  • banking
  • attribution of profits
  • interest deduction
  • tax treaty
  • withholding tax
Label
ABN Amro Bank NV v Assistant Director of Income Tax International Taxation-I, Kolkata : Assistant Director of Income Tax International Taxation-I, Kolkata v Bank of Tokyo Mitsubishi Ltd : ITA nos 694 and 695/Kol/2002 (assessment years 1997-98 and 1996-99) and ITA no 899/Kol/2002 (assessment year 1992-93)
Instantiates
Publication
Label
ABN Amro Bank NV v Assistant Director of Income Tax International Taxation-I, Kolkata : Assistant Director of Income Tax International Taxation-I, Kolkata v Bank of Tokyo Mitsubishi Ltd : ITA nos 694 and 695/Kol/2002 (assessment years 1997-98 and 1996-99) and ITA no 899/Kol/2002 (assessment year 1992-93)
Publication

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