Lowy: the first PPT-case - Kluwer International Tax Blog
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Lowy: the first PPT-case - Kluwer International Tax Blog
On December 30th of last year, the Indian Income Tax Appellate Tribunal was the first “quasi judicial institution” to apply the PPT to a treaty-shopping arrangement.[1] The case concerned a dispute between a Luxembourg-based holding company, SC Lowy, and the Indian tax authorities. Facts of the case The Luxembourg holding company, SC Lowy, is owned by a company located on the Cayman Islands and has made investments all over the world, including …
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