Switzerland recently rescinded the unilateral application of the most favoured nation (MFN) provision in its Double Taxation Avoidance Agreement (DTAA) with India. The MFN provision is a fundamental non-discrimination standard in international economic relations.
Consider a scenario where State A signs a bilateral treaty with State B that includes an MFN provision. If State A later grants benefits to a third country, State C, those benefits should also be extended to State B due to the MFN clause. Switzerland's recent decision is not retaliatory but rather a reciprocal action stemming from a ruling issued by the Supreme Court of India in October 2023 in the case of Assessing Officer v. Nestlé. In this case, Nestlé sought a preferential dividend tax rate of 5%, instead of the standard 10%, by referencing the MFN provision in the India-Switzerland DTAA. Nestlé argued that India offered a lower dividend tax rate to companies from OECD member countries such as Colombia and Lithuania. The MFN provision in the India-Switzerland DTAA provides that the benefits given to a country "which is a member of the OECD" should be extended to the signatory state.
Denne historien er fra December 27, 2024-utgaven av Hindustan Times Lucknow.
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Denne historien er fra December 27, 2024-utgaven av Hindustan Times Lucknow.
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A play with an all-women cast enthralls Lucknowites
This year is turning into one of the most memorable years for the art and theatre lovers of the city.
Suhana Khan and Agastya Nanda spotted; are they going to ring in the New Year's together?
Actors Suhana Khan and Agastya Nanda started their careers together in the industry with Zoya Akhtar's The Archies (2023). Since then, they have been spotted spending time together, which has sparked dating rumours. Now, it looks like the rumoured couple is all set to spend the New Year's together.
Sanjay Gangnani: Like any young couple, we hope to plan a family when the time is right
ctor Sanjay Gangnani says, \"I am at peace knowing I stuck to my plan for 2024—to explore the OTT space.\"There's so much happening there, and finding something worthwhile was my priority. Television has given me a certain image, and I wanted to build on that. Fortunately, it worked out,\" says Gangnani reflecting on his journey of venturing into the OTT space this year.
DIY hack: How to use rosemary water for hair growth
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Hania Aamir alleges assault by event organisers in the US
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International Acts Have Set High Standards
Singer Sunidhi Chauhan says that with more international concerts happening in India, it has become a challenge for Indian acts to be at par with them
Making good films, not sequels, is more important: Imtiaz
This year, franchise films like Stree 2, Bhool Bhulaiyaa 3 and Pushpa 2: The Rule emerged as some of the biggest box-office successes.
Rohit's Insipid Captaincy Lets Australia Take Control
It was a slow trudge out, with head bowed, for India's captain Rohit Sharma.
With a bit of luck and lots of faith, you can get back to scoring big runs: Smith
You are one of the best batters on the planet and then, the centuries dry up. That's how fickle form can sometimes be.
Renuka and Deepti star as India women sweep ODI series vs WI
Renuka Thakur and Deepti Sharma delivered a bowling masterclass to trounce West Indies by five wickets and seal a dominant victory in the third and final ODI of the series at the Kotambi Stadium, Vadodara on Friday.
