Tax Treaty Interpretation and Tunnel Vision: The Supreme Court of India's American Express Decision

This article argues the Indian Supreme Court’s American Express ruling overlooked key treaty‑interpretation questions. Proper analysis of Articles 7(2), 7(3), and 26(2) under the Vienna Convention reveals far deeper issues than the judgment addressed. spkl.io/63327AN54J #IntlTax #TaxLaw

Income and Territory: A Purpose-based Reform of Income Sourcing Rules

This paper argues that modern tax systems must rethink source‑based taxation: existing rules are outdated, but purpose‑based reforms could make source a viable foundation for international taxation in a mobile, digital economy. spkl.io/63326A2Cau #TaxPolicy #IntlTax