The question whether a State can indulge in tax treaty override by enacting provisions in the domestic law which are inconsistent/ contrary to the provisions in the tax treaty has been the subject matter of considerable controversy. The author, an Accountant Member of the Income Tax Appellate Tribunal, has, in a presentation made at the annual assembly of the International Association of Tax Judges in Amsterdam, carefully analyzed the entire theory and law on the subject and explained it in the proper perspective.
The presentation will be of great utility to all tax professionals.
Presentation On Tax Treaty Override By Hon'ble Pramod Kumar, Member, ITAT (101.9 KiB, 3,407 hits)
Brilliant !!
THIS IS AN ILLUMINATING PRESENTATION OF AN ABSTRACT CONCEPT BY THE LEARNED AUTHOR.