Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
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