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Lowy: the first PPT-case - Kluwer International Tax Blog

Summary by 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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Kluwer International Tax BlogKluwer International Tax Blog

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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Kluwer International Tax Blog broke the news in on Monday, March 24, 2025.
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Luxembourg, Luxembourg District

Luxembourg, Luxembourg District

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