international taxation

International Taxation – Witholding Tax Rates and provisions

195. [(1)Any person responsible for paying to a non-resident, not being a company, or to a foreign company, any interest or any other sum chargeable under the provisions of this Act (not being income chargeable under the head “Salaries” shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier, deduct income-tax thereon at the rate..
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No great ambiguity in international tax laws – IT official

The Income Tax department today said there is no great ambiguity in international tax laws and the Government wants to have more transparency in deals. There are issues...debatable issues, but there is no great ambiguity in international tax laws, Director General of Income Tax, International Taxation, R N Dash, said on the sidelines of a CII event here.
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CBDT – Transfers / Postings of Additional/ Joint CITs in International Taxation and Transfer Pricing

CBDT Vide Order No. 81 of 2011 dated 9.5.2011, the CBDT has transferred & posted Additional/ Joint CITs in the Directorate of International Taxation & Transfer Pricing. Vide Order No. 82 of 2011 dated 9.5.2011, the CBDT has transferred & posted Deputy/ Assistant CITs.
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ICAI Commences Registration for the Certificate Course on International Taxation – Hyderabad

We are pleased to announce that the Committee on International Taxation of ICAI has decided to commence the next Batch of the Certificate Course on International Taxation in Hyderabad from Saturday 21st May, 2011.
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Budget 2011- Govt may not raise taxes, try to streamline international tax

The government is likely to plug loopholes in international taxation to swell its kitty, since it does not have too many options to raise taxes in the upcoming Budget due to proposed rates in new direct and indirect tax regimes and high inflation. R
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Advent of APA in TP regime

The arena of International taxation has always been quite complex as much as it has been exciting (for tax practitioners in particular). What with residency rules, PE provisions, TP regimes, 195 issues and DTAAs, in fact, it will be more exciting as
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Direct Tax Code-2010 Proposed Changes in respect of international taxation

Income shall be deemed to accrue in India if it accrues, directly or indirectly through or from transfer of a capital asset situated in India. However, the income from the transfer by a non?resident of any share or interest in a foreign company would not be considered as income, wherein at any time in twelve months preceding the transfer, the fair market value of the assets in India, owned, directly or indirectly, by the company, represent at least fifty per cent of the ..
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Payment made for computer software not Royalty and TDS u/s. 195 not applicable

A computer software when put into a media and sold, it becomes goods like any other audio cassette or painting on canvass or book. The amount paid by the assessee towards purchase of IXOS-eCON for R/3 50 users cannot be treated as payment of royalty taxable in India under Article 12 of DTAA between India and Singapore. Therefore, the assessee, in our opinion, is not liable to deduct tax at source.
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