Tag Archives: Rakesh Nangia

AdWords case: ITAT order favours tax department- Rakesh Nangia

Google India said it will dispute a $38.4 million tax demand after a tribunal ruled that its royalty payments to Google Ireland are taxable in India. The May 11 rulingis the latest in a six-year dispute over the tax treatment of payments made from Google India to Google Ireland for the use of its copyrighted AdWords software.

  1. Rakesh Nangia, Managing Partner shares his views on aforementioned story for following publications.
  • Business Standard
  • Bloomberg BNA


Flipkart-Walmart deal: Tax dept grapples with Tiger Global’s liability – Rakesh Nangia

As per public information, in proposed deal, shares of holding company Flipkart Singapore (i.e. a foreign company) would be transferred to Walmart. Generally, any gain arising from sale of shares of a foreign company is not liable to income tax in India. However, pursuant to Vodafone controversy, ‘indirect transfer’ provisions were introduced under domestic tax laws, providing that gains from transfer of shares of foreign company could be taxed in India, if such shares derive its value substantially from assets situated in India, which would be apparently satisfied in Flipkart’s case, since entire business of Flipkart is situated in India.

Flipkart-Walmart deal