The Resource Groupe Industrial Marcel Dassault and another v Director of Income Tax (International Taxation) : AAR Nos 846 and 847 of 2009

Groupe Industrial Marcel Dassault and another v Director of Income Tax (International Taxation) : AAR Nos 846 and 847 of 2009

Label
Groupe Industrial Marcel Dassault and another v Director of Income Tax (International Taxation) : AAR Nos 846 and 847 of 2009
Title
Groupe Industrial Marcel Dassault and another v Director of Income Tax (International Taxation) : AAR Nos 846 and 847 of 2009
Contributor
Subject
Language
eng
Summary
Judgment by the Authority for Advance Rulings (AAR) (Income tax), New Delhi, dated 28 November 2011. In 2006 a French company, Murieux Alliance, formed a French company, ShanH to acquire an 80% interest in an Indian company, Shantha. Later, Groupe Dassault and a French individual became shareholders in ShanH. In August 2009, Murieux Alliance and Groupe Dassault sold their shares in SHanH to Sanofi, another French company: two French companies sold to a French company shares in a French company which owned a controlling interest in an Indian company. The vendors sought an advance ruling that they were not taxable in India. The AAR, refusing in part the ruling, held that this was an arrangement to avoid Indian tax on the sale of shares in an Indian company. By the sale of shares in a French company, the control over the Indian company could be transferred without exposure to Indian tax. The AAR held that the transfer of an interest in an Indian company could be taxed in India
Citation source
In: International tax law reports. - London. - Vol. 14 (2012),
Geographic coverage
  • Europe
  • European Union
  • Asia
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • advance tax ruling
  • tax treaty
  • tax avoidance
  • capital gains tax
  • substance over form
Label
Groupe Industrial Marcel Dassault and another v Director of Income Tax (International Taxation) : AAR Nos 846 and 847 of 2009
Instantiates
Publication
Label
Groupe Industrial Marcel Dassault and another v Director of Income Tax (International Taxation) : AAR Nos 846 and 847 of 2009
Publication

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