international taxation

Complete NRI Guide to Property in India

Income Tax - This article attempts to dispel the doubts in the minds of such prospective NRI investors by addressing key issues pertaining to property dealings in India....

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Does constitution of “Service PE” entail physical presence of foreign personnel in host country?

Income Tax - Permanent Establishment (PE) is the fundamental criterion under the tax treaties for taxation of foreign company’s business income in India. A permanent establishment of a foreign company is typically regarded as a virtual extension or taxable presence of such foreign company in the host country, similar to that of an independent legal ...

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POEM – Tracking the evolution of new Residency Norm

Income Tax - Place of Effective Management (PoEM) has been one of the most deliberated aspects under the Indian Income Tax regime since its introduction vide Finance Act, 2015, especially for Indian transnational groups....

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U S Taxation Vs Canadian Income Tax for individual- a Study

Income Tax - During my recent visit to Southern India, particularly, Tamil Nadu, my family doctor having many covenanted degrees in Medicine from Canada, mentioned about the high income/other tax rates in Canada and also their social commitments to take extra care of the welfare of their citizen. ...

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Computation of Interest Income Pursuant to Secondary Adjustments

Income Tax - Finance Act, 2017 inserted a new Section 92CE in the Income-tax Act, 1961 with effect from 1st day of April, 2018 to provide for secondary adjustment by attributing income to the excess money lying in the hands of the associated enterprise....

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Cabinet approves MOC in respect of tax matters with BRICS countries

Income Tax - Cabinet approves MOC in respect of tax matters between India and BRICS countries – Brazil, Russia, China and South Africa The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has given the approval for the signing of Memorandum of Cooperation (MOC) in respect of tax matters between India and the Revenue administrations...

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India Signs MLC to Prevent Base Erosion and Profit Shifting

Income Tax - Finance Minister Shri Arun Jaitley signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting at Paris on 7th June, 2017 on behalf of India....

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Cyprus seeks Indian investments to enhance ties: Nicos Anastasiades

Income Tax - President of the Republic of Cyprus urged Indian industry to invest in the country`s key areas including banking and finance, shipping and transportation, education, science and technology, pharmaceuticals, renewable energy and tourism in order to stimulate trade and investments between the two countries said at `India –Cyprus Business ...

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Name Change? How It Impacts Taxes in USA

Income Tax - A name change can have an impact on taxes. All the names on a taxpayer’s tax return must match Social Security Administration records. A name mismatch can delay a tax refund. Here’s what taxpayers should know if they changed their name:...

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IRS Reminds International Taxpayers of Tax Obligations; Clarifies Rules for Tax Withholding Agents

Income Tax - The Internal Revenue Service today reminded non-U.S. citizens who may have taxable income, such as international students and scholars who may be working or receiving scholarship funds, that they may have special requirements to file a U.S. tax return....

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Payment for Net Communication system developed by principal for smooth functioning of shipping business is not FTS

DIT Vs. A. P. Moller Maersk, (Supreme Court) - In this Case Hon’ble Supreme Court held that Payments made by the agents to the concerned foreign assessee, for using the facility of Net Communication System, developed by the assessee for smooth functioning of its international shipping business cannot be classified as fees for technical ser...

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Taxability of business done by NRI through Power of Attorney holder

Carpi Tech SA Vs ADIT (ITAT Chennai) - Assessee submitted that project receipt from Tanakpur Power Project of NHPC work is exempt from tax in India for the reason that assessee does not have continuous presence or 'business connection' or a permanent establishment in India....

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TP – Notional Interest on Excess Credit Period/ Delayed Payment

Tally Solutions Pvt. Ltd. Vs. ACIT (ITAT Bangalore) - The treatment of extended credit period to Associated Enterprises(AEs) as an international transaction and making adjustment of notional interest on the same has always been bone of contention between the assessee and department. ...

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TDS not deductible on web hosting & marketing services procured from US based entity

DCIT Vs M/s Matrimony.Com Pvt. Ltd. (ITAT Chennai) - The ITAT Chennai held that payments made by the assessee in the nature of webhosting and marketing expenses to US based service provider could not be taxed as Fees for technology services because there were not transfer of technology involved in render of services such that the services could be con...

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Section 94-A(1) is Constitutional Valid : Madras High Court

T. Rajkumar & Others Vs UOI & Ors. (Madras High Court) - The Hon'ble Madras High court in the above cited case held that central govt can notify a country as notified jurisdictional area u/s 94A inspite of the fact that there exist a Double Tax Avoidance Agreement provided the DTAA is not serving the intended purpose for which it was entered into. ...

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Draft Notification on foreign company resident in India U/s. 115JH

F No 370142/19/2017-TPL - (15/06/2017) - CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961...

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Reg. removal of Cyprus from list of notified jurisdictional areas U/s. 94A

Circular No. 15/2017-Income Tax - (21/03/2017) - It is hereby clarified that Notification No. 86/2013 has been rescinded with effect from the date of issue of the said notification, thereby, removing Cyprus as a notified jurisdictional area with retrospective effect from 01.11.2013....

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Principles for determination of Place of Effective Management (POEM) of a Company

Circular No. 06/2017-Income Tax - (24/01/2017) - Section 6(3) of the Income-tax Act, 1961 (the Act), prior to its amendment by the Finance Act, 2015, provided that a company is said to be resident in India in any previous year, if it is an Indian company or if during that year, the control and management of its affairs is situated wholly in India....

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CBDT notifies Protocol between India and Cyprus

Notification No. 03/2017-Income Tax - (10/01/2017) - Protocol between India and Cyprus for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income ...

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CBDT notifies rules for Foreign Tax Credit

Notification No. 54/2016-Income Tax - (27/06/2016) - Foreign Tax Credit.- (1) An assessee, being a resident shall be allowed a credit for the amount of any foreign tax paid by him in a country or specified territory outside India, by way of deduction or otherwise, in the year in which the income corresponding to such tax has been offered to tax or ass...

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Recent Posts in "international taxation"

Cabinet approves MOC in respect of tax matters with BRICS countries

Cabinet approves MOC in respect of tax matters between India and BRICS countries – Brazil, Russia, China and South Africa The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has given the approval for the signing of Memorandum of Cooperation (MOC) in respect of tax matters between India and the Revenue administrations...

Read More
Posted Under: Income Tax |

Complete NRI Guide to Property in India

This article attempts to dispel the doubts in the minds of such prospective NRI investors by addressing key issues pertaining to property dealings in India....

Read More
Posted Under: Income Tax |

Does constitution of “Service PE” entail physical presence of foreign personnel in host country?

Permanent Establishment (PE) is the fundamental criterion under the tax treaties for taxation of foreign company’s business income in India. A permanent establishment of a foreign company is typically regarded as a virtual extension or taxable presence of such foreign company in the host country, similar to that of an independent legal ...

Read More
Posted Under: Income Tax |

POEM – Tracking the evolution of new Residency Norm

Place of Effective Management (PoEM) has been one of the most deliberated aspects under the Indian Income Tax regime since its introduction vide Finance Act, 2015, especially for Indian transnational groups....

Read More
Posted Under: Income Tax |

U S Taxation Vs Canadian Income Tax for individual- a Study

During my recent visit to Southern India, particularly, Tamil Nadu, my family doctor having many covenanted degrees in Medicine from Canada, mentioned about the high income/other tax rates in Canada and also their social commitments to take extra care of the welfare of their citizen. ...

Read More
Posted Under: Income Tax |

Computation of Interest Income Pursuant to Secondary Adjustments

Finance Act, 2017 inserted a new Section 92CE in the Income-tax Act, 1961 with effect from 1st day of April, 2018 to provide for secondary adjustment by attributing income to the excess money lying in the hands of the associated enterprise....

Read More
Posted Under: Income Tax |

Draft Notification on foreign company resident in India U/s. 115JH

F No 370142/19/2017-TPL (15/06/2017)

CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961...

Read More

Revision of Safe Harbour Rules: A Positive Thought!

In India, new transfer pricing rules were introduced in 2002. Since then, the number of cases identified for audit and the transfer pricing adjustments locked up in disputes have increased tremendously. In order to reduce the increasing number of transfer pricing audits and prolonged disputes...

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Posted Under: Income Tax |

Safe Harbour Rules- Eligible International Transactions

Prabhakar K S  [Ilaya Azwan] The Central Board Of Direct Taxes (CBDT) Vide Notification No. 46/2017 Date 7th June, 2017 Notifies Revised List Of ‘Eligible International Transactions’ For Transfer Pricing Safe Harbour Rules. Sl. No. Eligible International Transactions Circumstances   01 Software Development Services Operating Pr...

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Posted Under: Income Tax |

India Signs MLC to Prevent Base Erosion and Profit Shifting

Finance Minister Shri Arun Jaitley signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting at Paris on 7th June, 2017 on behalf of India....

Read More
Posted Under: Income Tax |
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