The Resource Sanofi Pasteur Holding SA v Department of Revenue and others : WP Nos 14212 of 2010, 3339 and 3358 of 2012 and related appeals

Sanofi Pasteur Holding SA v Department of Revenue and others : WP Nos 14212 of 2010, 3339 and 3358 of 2012 and related appeals

Label
Sanofi Pasteur Holding SA v Department of Revenue and others : WP Nos 14212 of 2010, 3339 and 3358 of 2012 and related appeals
Title
Sanofi Pasteur Holding SA v Department of Revenue and others : WP Nos 14212 of 2010, 3339 and 3358 of 2012 and related appeals
Creator
Subject
Language
eng
Summary
Judgment by the High Court of Judicature, Andhra Pradesh at Hyderabad dated 15 February 2013. Two shareholders, Merieux Alliance (MA) and Groupe Industriel Marcel Dassault (GIMD), both resident in France, disposed of shares in a French company, ShanH SAS (ShanH), which had a controlling interest in an Indian company Shanta Biotechnics Ltd (SBL). ShanH appeared to carry on no other business than holding the shares in SBL. MA and GIMD then decided to sell ShanH to Sanofi. Sanofi purchased all the shares in ShanH and MA and GIMD paid tax in France on their capital gains. The Indian Revenue authorities sought to tax the gain on the disposal of the shares in the French company on the grounds that it was an indirect disposal of a controlling interest in the Indian company SBL. MA and GIMD relied, amongst other things, on the capital gains article on the France-Indian double taxation agreement
Citation source
In: International tax law reports. - London. - Vol. 15 (2013),
http://bibfra.me/vocab/relation/comm
SHyl_bl3bsg
http://library.link/vocab/creatorName
Baker, P
Geographic coverage
  • Asia
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • double taxation
  • tax avoidance
  • capital gains
  • disposal
  • treaty interpretation
Label
Sanofi Pasteur Holding SA v Department of Revenue and others : WP Nos 14212 of 2010, 3339 and 3358 of 2012 and related appeals
Instantiates
Publication
Label
Sanofi Pasteur Holding SA v Department of Revenue and others : WP Nos 14212 of 2010, 3339 and 3358 of 2012 and related appeals
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...