Dr. Amar Mehta

Video Discussions on International Tax Issues


On Dr. Mehta's other website (dramarmehta.com), there are many video discussions on important international tax issues.

The following are some of the topics that are dealt with in those video discussions:

  • Can subsequent domestic tax law amendments govern tax treaty interpretation? (Focussing on a decision of the Supreme Court of Denmark.) Published here.
  • Tax treatment of oil and gas royalties: immovable property income (Art. 6) or business income (Art. 7)? Link.
  • EPC contracts controversy: is income from supervision activities fees for technical services (FTS)? Link
  • Can competent authorities' resolutions under mutual agreement procedure (MAP) bind courts? Link
  • Canadian Supreme Court's landmark decision on GAAR. Link
  • Can an ordinance override a tax treaty? Link
  • Are Luxembourg SICAVs entitled to tax treaty benefits? Link
  • Stock options: tax treaty controversy. Link
  • Triangular cases: can one tax treaty cancel out benefits under another tax treaty? Link
  • Beneficial ownership: The Danish Supreme Court's landmark decision (two episodes). (Episode 1, Episode 2)
  • Danish ruling: warehouse could not give rise to a PE. Link
  • Beneficial ownership: can that requirement be impliedly read into the capital gains article in tax treaties? Link
  • Permanent establishment and income attribution: the Indian Supreme Court's landmark decision. Link
  • Could an e-commerce fulfilment arrangement give rise to a PE? Link
  • Art. 10 Dividends: 21 Landmark Decisions from 14 Jurisdictions. 11 Episodes: E1, E2, E3, E4, E5, E6, E7, E8, E9, E10, E11
  • Could a transfer pricing adjustment for a domestic enterprise lead to 'dividend' characterization (under tax treaty) for the associated enterprise? Episode 1, Episode 2
  • Variable interest on loans: tax treaty characterization as dividends (Art. 10) or interest (Art. 11)? Link
  • Could notional interest be treated as disguised dividend? Link
  • Could an indirect shareholder be considered as a shareholder for the purpose of a tax treaty? Link
  • Can a tax residence certificate (TRC) be accepted as proof for bench ownership? Link
  • Beneficial ownership: multi-jurisdictional jurisprudence (two episodes). Episode 1; Episode 2
  • Beneficial ownership: how should that tax treaty term be interpreted? Link
  • Beneficial ownership: two very important decisions. Link
  • The MFN clause: Dutch Supreme Court's landmark decision. Link
  • A recent controversial case: can income from transaction (not involving activities in India) between two foreign companies be taxed in India? Link