ISSN (Print) - 0012-9976 | ISSN (Online) - 2349-8846
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The Untold Story

Tax Residency Certifi cates

The budget proposal that a tax residency certifi cate is a necessary but not suffi cient condition to access treaty benefi ts triggered a slide in the Sensex prompting the government to issue a clarifi cation that the tax authorities in India will not go behind the TRC and question the residential status of the taxpayer. This article examines the issue of TRCs from the time of the opening up of the economy. It examines the observations of the courts and joint parliamentary committees, and international jurisprudence and argues that the Government of India in a very non-transparent manner is allowing treaty shopping to continue unabated.

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