International Trend of Taxing Indirect Transfers by Nonresidents Continues
October 5, 2010 in International Tax Monitor
By Alan Winston Granwell, Peng Tao, and Stephen Weerts, DLA Piper LLP (U.S.).
The Mumbai High Court recently ruled that Vodafone International Holdings B.V., a wholly owned Dutch subsidiary of Vodafone Group plc, the U.K. telecommunications company, was liable for withholding Indian capital gains tax in connection with its 2007 indirect acquisition of a 67 percent interest in Indian cellular operator Hutchison Essar.
Hutchison Essar was a lower-tier subsidiary of Hutchison Telecommunications International Ltd., a Cayman Islands company listed in Hong Kong and New York. This case has been the subject of a great deal of interest because the Indian tax authorities asserted that India had tax jurisdiction over an acquisition made wholly outside of India between non-Indian companies…
The full version of this article is in the BNA International Tax Centre.
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