Presentations
Taxation of Intellectual property rights (including software taxation) [May 2026] New
Abstract: The taxation of intellectual property rights has been contentious over the past two decades. The litigation in the courts over payments for software, broadcasting, films, and streaming has not provided the required clarity. The presentation explores the various facets of intellectual property law, including copyrights, patents, and trademarks, through practical case studies and offers some answers.
Abstract: A concise overview of the Black Money Act, 2015, covering taxation of undisclosed foreign income and assets, compliance requirements, penalties, prosecution provisions, and recent developments relevant to tax professionals.
Entitlement to Treaty Benefit [January 2026]
Limitation of Benefits Clause in Indian DTAAs and SLoBin Article 7 of MLI
Tax treaty benefits—the MLI conundrum [Dec 2025]
Abstract: In this podcast, CA Ganesh Rajgopalan is in conversation with CA Abbas Jaorawala regarding the controversy over the notification requirement for the BEPS Multilateral Instrument (MLI). The podcast covers the Nestlé SA ruling (CIVIL APPEAL NO(S). 1420 OF 2023) pronounced by the Hon’ble Supreme Court in 2023 as well as Sky High Leasing Co. Ltd. v. ACIT [2025] ITA No. 1198/Mum/2025 of the Income-tax Appellate Tribunal, which followed the Nestlé SA ruling to hold that a separate notification is required for the provisions of the MLI to modify the Double Tax Avoidance Agreements.
The Bombay Chartered Accountants’ Society hosted the podcast in December 2025.
Link: https://www.youtube.com/watch?v=LjtpybzSljM
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Interpretation of MLI - [Nov 2024]
Abstract : The Multilateral Instrument signed in 2016 to give effect to the BEPS measures in treaties, gives rise to interesting issues for interpretation. The Presentation describes the conflict between the Covered Tax agreement and the MLI and the application of the compatibility clauses in the MLI which act as conflict rules. The various tools for interpretation of the MLI based on the articles of the Vienna Convention are enumerated. The impact of notifications mismatch on the CTA is explored. How and to what extent treaties entered into by India are impacted is discussed though interesting examples. Mismatch of notifications and inappropriate reservations made as well as the usefulness (or lack of it) of the Synthesised Texts are discussed.
Tax Treaties and MLI - Interpretation and Interplay [April 2023]
Abstract: The Multilateral Instrument (MLI) impacts several double tax avoidance agreements entered into by several countries. This presentation describes the conflict rules (compatibility clauses) contained in the MLI. The extent India's tax treaties are modified by several articles of the MLI is then examined through four case studies.
Taxation of Software Payments [March 2021]
Abstract: An analysis of Engineering Analysis ruling (Supreme Court)
MLI Article 13 on Specific Activities Exemption - A case study [August 2020]
Abstract: That the Multilateral Instrument modifies the Covered Tax Agreements is well-known. However, the nature and the extent of the impact on the CTAs is not well documented. This presentation explores the effect of MLI Article 13 with respect to specific activities exemptions on India's treaties with Australia and the United Kingdom through a case study.
Abstract: The Presentation describes the Indian General Anti Avoidance Rules introduced in the Income-Tax Act, 1961 with effect from 1st April, 2017.