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Ca Nitin Bhatia

Latest Posts by Ca Nitin Bhatia

Common strategies used to avoid Permanent Establishment status

November 20, 2020 6744 Views 0 comment Print

Avoidance of Permanent Establishment (PE) status of Non-Residents are made through various arrangements. Company structures their business in way that status of PE can artificially be avoided. The definition of permanent establishment included in tax treaties is therefore crucial in determining whether a non-resident enterprise must pay income tax in another jurisdiction. Strategies used to […]

Analysis of Section 172 applicable on Profit of foreign Shipping Company

October 22, 2020 36747 Views 2 comments Print

Section 172 of income tax act is a special provision which deals with levy and recovery tax from foreign shipping companies. It specifies that every foreign shipping company has to declare a certain percentage of profit on its freight income and pay tax on it.

Limitation of interest deduction- section 94B – Thin Capitalization

October 20, 2020 9468 Views 0 comment Print

Many countries limit the amount of interest expenses of multinational companies (MNC). An enterprise who has borrowed capital in form of loan from its associate enterprises can claim deduction of interest paid and payable to associated enterprises. Foreign companies have several models to infuse capital in its associated company situated in another country. Some may […]

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