The evolution of taxation of equity share buybacks in India has undergone a tumultuous journey over the recent years giving rise to a tangle of consequences that have become evident in practice. The latest Infosys buyback, priced at ₹1,800 per share with an 18% premium over the market rate is a glaring example of the challenges embedded in the legal framework evolved after the Finance Act (“FA”) amendment of 2024 which deemed the entire buyback consideration as dividend incom

In the 21st century, the world has witnessed unprecedented globalisation, with many MNCs venturing into global investments and generating substantial revenue. This international context is crucial to understanding the dynamics of Double Taxation Agreements and the Mutual Agreement Procedure (MAP) for resolving tax disputes, which aim to prevent Double Taxation.[1] However, there are drawbacks within MAPs due to firstly(i) the duration of time it took; secondly(ii) there w

Corporate restructuring through demergers has emerged as a significant mechanism through which companies reorganize internal business structures, enhance operational efficiency, and unlock shareholder value. In principle, such restructuring should occur without triggering adverse tax consequences where there is no substantive change in ownership or economic control. The Indian tax framework governing demergers seeks to achieve this objective through the principle of tax neutr