Does the Issue of Shares by a Subsidiary Company to a Foreign Holding Company Amount to Taxable Income in the Hands of the Issuing Company? Vodafone India Services Pvt Ltd v Union of India
Journal of Contemporary Roman-Dutch Law, Vol. 80, p. 412-431, 2017
20 Pages Posted: 12 Dec 2017
Date Written: August 9, 2017
This article discusses two inter-twined issues that arose in the Indian case of Vodafone India Services Pvt Ltd v Union of India, namely (a) whether the issue of shares by a subsidiary to its non-resident parent company is a taxable transaction; and (b) whether the issue of equity shares by a subsidiary to its holding company at a value lower than the fair market value falls under the transfer pricing provisions.
Keywords: Issue of Shares, Subsidiary Company, Foreign Holding Company, Taxable Transaction, Transfer Pricing Provisions
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