India Taxation on ESOPs: No Treaty Protection for UAE Residents Without Direct Employment Nexus.

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....Accrual of income in India - Taxation of ESOP benefit - In the absence of nexus of ‘other similar benefits’, as wages and salaries, received by the assessee vis-à-vis his employment in the U.A.E., the treaty protection of the said income in India cannot be available to a resident of the U.A.E. - AT....