The Resource Verizon Communications Singapore Pte Ltd v Income Tax Officer : Tax case (Appeal) Nos 147 to 149 of 2011 and 230 of 2012

Verizon Communications Singapore Pte Ltd v Income Tax Officer : Tax case (Appeal) Nos 147 to 149 of 2011 and 230 of 2012

Label
Verizon Communications Singapore Pte Ltd v Income Tax Officer : Tax case (Appeal) Nos 147 to 149 of 2011 and 230 of 2012
Title
Verizon Communications Singapore Pte Ltd v Income Tax Officer : Tax case (Appeal) Nos 147 to 149 of 2011 and 230 of 2012
Creator
Contributor
Subject
Language
eng
Summary
Judgment by the High Court of Judicature at Madras, judgment date 7 November 2013. The taxpayer was a Singapore company which offered dedicated internet communication typically between company branches or associated companies. Customers paid for an agreed amount of bandwidth to be available to them. Owing to regulatory requirements, services in India had to be provided by a company licensed in India. Links from India to destinations overseas were therefore provided in two legs, from the Indian customers to a point overseas by the Indian company and then from that point to anywhere else in the world by the taxpayer. The taxpayer was assessed for tax in India on the basis that the payments made by its customers in India were royalties paid for the use of "industrial, commercial or scientific equipment", in which case under the India-Singapore double taxation agreement, they could be taxed in India. The taxpayer objected, arguing that the payments were for services provided. The taxpayer argued that the allocation of bandwidth was merely a guarantee of level of service and did not imply an economic interest in the taxpayer's facilities. The main issue therefore was whether the payment made by Indian customers for the provision of this bandwidth service outside India was a royalty or not
Citation source
In: International tax law reports. - London. - Vol. 16 (2014),
http://bibfra.me/vocab/relation/comm
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http://library.link/vocab/creatorName
Goradia, S
Geographic coverage
Asia
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • services
  • royalties
  • internet
Label
Verizon Communications Singapore Pte Ltd v Income Tax Officer : Tax case (Appeal) Nos 147 to 149 of 2011 and 230 of 2012
Instantiates
Publication
Label
Verizon Communications Singapore Pte Ltd v Income Tax Officer : Tax case (Appeal) Nos 147 to 149 of 2011 and 230 of 2012
Publication

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