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DTAA

Latest Articles


From Double Taxation to Treaty Shopping: Unfolding Saga of India-Mauritius DTAA

Income Tax : Explore the India-Mauritius DTAA's impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fos...

October 7, 2024 996 Views 0 comment Print

U.S. LLCs with Separate Legal Identity Eligible for Treaty Benefits: Key crux of General Motors case

Income Tax : Explore how LLCs qualify for India-US DTAA benefits, focusing on tax liability and resident status under Article 4 in the General ...

September 25, 2024 624 Views 0 comment Print

Form No. 10F under the Income Tax Act

Income Tax : Form No. 10F is a self-declaration for NRIs to claim benefits under DTAA when their Tax Residency Certificate lacks essential deta...

September 24, 2024 4593 Views 0 comment Print

Breaking Down Latest Five High Court Decisions on Income Tax Issues

Income Tax : Explore five recent High Court decisions on income tax issues, including DTAA, FTS classification, MAT inclusion, reassessment ord...

September 9, 2024 1854 Views 0 comment Print

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications f...

September 3, 2024 39187 Views 1 comment Print


Latest News


Representation to Simplify & Automate TRC Issue Process for Indian Companies

Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...

June 22, 2024 285 Views 0 comment Print

India-Cyprus Double Tax Treaty: Benefits, Tax Recovery & Golden Passport

Income Tax : Explore the details of India's Double Tax Treaty with Cyprus, its signing date, benefits for both nations, tax recovery provisions...

December 11, 2023 927 Views 0 comment Print

Need for amendment of DTAA to stop double taxation of Indian IT firms

Income Tax : Need for early amendment of DTAA regulations to stop the double taxation of Indian IT firms: Ms. Anupriya Patel tells the visiting...

July 24, 2022 828 Views 0 comment Print

Cabinet approves Agreement with Saint Vincent for Tax Information exchange

Income Tax : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...

June 23, 2021 723 Views 0 comment Print

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...

March 19, 2020 420 Views 0 comment Print


Latest Judiciary


Foreign Tax Credit eligible for taxes withheld in Japan: ITAT Mumbai

Income Tax : ITAT Mumbai held that services rendered by the appellant is taxable in Japan in accordance to Article 12 of the India-Japan DTAA h...

November 11, 2024 288 Views 0 comment Print

No TDS liability u/s 195 on sales commission paid to overseas subsidiary for non-technical services as same was not ‘FTS’

Income Tax : Sales and marketing services rendered to assessee by its US based subsidiary did not fall within the ambit of FTS as defined u/s 9...

October 29, 2024 573 Views 0 comment Print

Interest payments to China Development Bank exempt under India-China DTAA: Delhi HC

Income Tax : CDB qualifies as a financial institution wholly owned by Government of China, thereby making interest payments exempt from taxatio...

October 27, 2024 135 Views 0 comment Print

Taxation of shipping companies operating in international waters & applicability of India-Singapore DTAA

Income Tax : Atlantic Shipping Pvt. Ltd. Vs ITO (ITAT Rajkot) In a recent ruling by the Income Tax Appellate Tribunal (ITAT) in Rajkot, the cas...

October 16, 2024 186 Views 0 comment Print

LLC as Fiscally Transparent Entity Under US Law eligible for India-USA DTAA Benefits

Income Tax : The article analyzes the treatment of LLCs under the India-USA DTAA, focusing on taxation implications for foreign entities in Ind...

September 30, 2024 375 Views 0 comment Print


Latest Notifications


CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...

March 19, 2024 3015 Views 0 comment Print

CBDT notifies Tax Information Exchange Agreement: India-Samoa

Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...

February 7, 2024 951 Views 0 comment Print

Income Tax Agreement Between India & Saint Vincent for information Exchange

Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...

November 1, 2023 639 Views 0 comment Print

DTAA between India and Chile notified by CBDT

Income Tax : Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Pro...

May 3, 2023 2730 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4473 Views 0 comment Print


Latest Posts in DTAA

Foreign Tax Credit eligible for taxes withheld in Japan: ITAT Mumbai

November 11, 2024 288 Views 0 comment Print

ITAT Mumbai held that services rendered by the appellant is taxable in Japan in accordance to Article 12 of the India-Japan DTAA hence Foreign Tax Credit ought to have been granted to Appellant for taxes withheld in Japan.

No TDS liability u/s 195 on sales commission paid to overseas subsidiary for non-technical services as same was not ‘FTS’

October 29, 2024 573 Views 0 comment Print

Sales and marketing services rendered to assessee by its US based subsidiary did not fall within the ambit of FTS as defined u/s 9(1)(vi) or Article 12 of India-US DTAA as  making available service did not make available knowledge, experience, skill etc.

Interest payments to China Development Bank exempt under India-China DTAA: Delhi HC

October 27, 2024 135 Views 0 comment Print

CDB qualifies as a financial institution wholly owned by Government of China, thereby making interest payments exempt from taxation under amended provisions of DTAA.

Taxation of shipping companies operating in international waters & applicability of India-Singapore DTAA

October 16, 2024 186 Views 0 comment Print

Atlantic Shipping Pvt. Ltd. Vs ITO (ITAT Rajkot) In a recent ruling by the Income Tax Appellate Tribunal (ITAT) in Rajkot, the case of Atlantic Shipping Pvt. Ltd. vs. Income Tax Officer has brought to light critical issues regarding tax assessments for shipping companies operating in international waters and the applicability of the India-Singapore Double […]

From Double Taxation to Treaty Shopping: Unfolding Saga of India-Mauritius DTAA

October 7, 2024 996 Views 0 comment Print

Explore the India-Mauritius DTAA’s impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fostering genuine investments.

LLC as Fiscally Transparent Entity Under US Law eligible for India-USA DTAA Benefits

September 30, 2024 375 Views 0 comment Print

The article analyzes the treatment of LLCs under the India-USA DTAA, focusing on taxation implications for foreign entities in India.

Cloud Subscription Fees Not Royalty under India-Ireland DTAA: ITAT Delhi

September 30, 2024 261 Views 0 comment Print

ITAT Delhi rules that subscription fees from cloud services are not taxable as royalty under the India-Ireland DTAA. 

U.S. LLCs with Separate Legal Identity Eligible for Treaty Benefits: Key crux of General Motors case

September 25, 2024 624 Views 0 comment Print

Explore how LLCs qualify for India-US DTAA benefits, focusing on tax liability and resident status under Article 4 in the General Motors vs ACIT case.

Form No. 10F under the Income Tax Act

September 24, 2024 4593 Views 0 comment Print

Form No. 10F is a self-declaration for NRIs to claim benefits under DTAA when their Tax Residency Certificate lacks essential details.

Damages is capital receipt but interest on damages is revenue receipt: ITAT Delhi

September 24, 2024 372 Views 0 comment Print

ITAT Delhi held that damages are compensation received is a capital receipt, however, interest on damages is to be treated as revenue receipt hence the same is taxable.

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