Top Notch International Tax Judgments - December 2025



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This article reviews significant international tax judgments from December 2025, offering insights into rulings that impact businesses operating globally. It covers four key cases decided by Indian High Courts, addressing issues such as whether payments for international private leased circuits constitute royalty, the deductibility of head office expenses for non-residents, the permissibility of refunds for foreign shareholders concerning pre-2020 dividend distribution tax, and the definition of a permanent establishment in the context of remote service provision.

As I write this missive, I realize that the year 2025 has come to an end. The calendar year marked notable events. However, some disasters took place, like a major flight accident and Indigo operations coming to a halt. This year saw many reverse flip transactions taking place and some key demergers taking place. This year is on the brink of coming to an end; a new year is beginning. Before analyzing the judgment of international taxation, let me describe a key economic event. Saga of Rupee v
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About the Author

International tax professional at Solique Advisors and Solutions Service Private Limited(erstwhile In VCAJ associates LLP)

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