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This past January, the Supreme Court in India ruled in Vodafone International Holdings B.V v. Union of India,Civil Appeal No. 733 of 2012 (arising from S.L.P. (C) No. 26529 of 2010) that the sale of stock of a company that was non-resident in India to another non-resident company was not subject to income tax in India
A issue of some significance in international taxation is the distinction required to be made by the taxing authorities as to the character of income derived from “shrink-wrapped” software, i.e., whether it is income from the license of a copyright itself or is income from a copyrighted article
