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DTAA

Latest Articles


Switzerland Suspends Unilateral MFN Clause Application in Tax Treaty with India

Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...

March 4, 2025 270 Views 0 comment Print

Taxation of International Transactions In India Under Income Tax Act 1961

Income Tax : Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, ...

February 9, 2025 1950 Views 0 comment Print

How Switzerland revoking MFN Status with India linked to Nestle Case?

Income Tax : Switzerland suspends the MFN clause with India following a Supreme Court ruling in the Nestle case, impacting dividend tax rates f...

December 22, 2024 1107 Views 2 comments Print

Taxation of Indian & Overseas IPL Players

Income Tax : Explore the tax implications for IPL players, including income tax for Indian and overseas players, TDS rates, and the role of DTA...

December 18, 2024 2424 Views 0 comment Print

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 1173 Views 0 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 366 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 1014 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 441 Views 0 comment Print


Latest Judiciary


No TDS on Payments to Non-Residents for Social Media Ads: Karnataka HC

Income Tax : Karnataka High Court held that TDS is not deductible on payment to non-residents for advertisements in several social medias like ...

February 22, 2025 201 Views 0 comment Print

Reimbursement of expense at cost not taxable as Fees for Technical Services

Income Tax : ITAT Mumbai held that that reimbursement of expenses at cost is not taxable as fees for technical services since there is no eleme...

February 15, 2025 213 Views 0 comment Print

Indian AE Transactions at Arm’s Length, HC Says No More Attribution

Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...

February 13, 2025 120 Views 0 comment Print

IT support payments not taxable as FTS due to failure of ‘make available’ test under India-UK DTAA: ITAT Delhi

Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...

February 9, 2025 276 Views 0 comment Print

Carried forward losses cannot be set-off against exempt capital gains under DTAA

Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...

February 8, 2025 456 Views 0 comment Print


Latest Notifications


Guidance on Principal Purpose Test (PPT) in India’s DTAAs

Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...

January 21, 2025 3270 Views 0 comment Print

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 3309 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 984 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 660 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 2997 Views 0 comment Print


Delhi High Court Closes CCD Taxation Appeals, Awaits Supreme Court’s Final Decision

January 16, 2024 966 Views 0 comment Print

Delhi High Court disposes of CIT Vs Zaheer Mauritius appeals, addressing taxability and capital gains nature of Compulsorily Convertible Debentures under India-Mauritius DTAA.

BEPS Principles and MLI Framework in India’s PE Status under DTAA

January 15, 2024 1584 Views 0 comment Print

Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.

Receipt in terms of Strategic Oversight Services Agreement cannot be termed as royalty

January 6, 2024 669 Views 0 comment Print

Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services.

Exploring The Emerging Areas of International Taxation

January 5, 2024 975 Views 0 comment Print

Explore the dynamic landscape of international taxation, delving into emerging areas like digital companies, cross-border transactions with cryptocurrencies, and the evolving tax landscape for multinational corporations. Stay informed on transfer pricing regulations and ensure compliance for a seamless global business experience.

Form 10F Guide: Tax Treaty Benefits for Non-Resident Receiving Indian Income

January 5, 2024 26652 Views 3 comments Print

Understand Form 10F for non-residents receiving income from India. Learn about electronic filing, recent changes, and the benefits of claiming tax treaty relief with Tax Residency Certificate (TRC).

Decoding Grant Thornton Case: Impact on Cross-Border Transactions

January 4, 2024 1155 Views 0 comment Print

Explore Grant Thornton India LLP case, unraveling complex international tax issues. Analysis of arguments, rulings, and broader implications for businesses in cross-border transactions.

No Profit Attribution if Ricardo India’s Commission Adjusted: Delhi HC

January 2, 2024 627 Views 0 comment Print

Explore Delhi High Court’s ruling in CIT vs Ricardo U.K. Limited. No profit attribution if commission paid to Ricardo India is adjusted against PE profit. Detailed analysis and implications.

Taxation of IPL Income under Section 115BBA of Income Tax Act 1961 for Mitchell Starc & Pat Cummins

December 31, 2023 8520 Views 0 comment Print

Explore tax implications of Mitchell Starc and Pat Cummins’ Rs. 45.25 crores IPL earnings under Section 115BBA. Learn about TDS, exemptions, and dual taxation agreements between India and Australia.

Recent Developments in International Taxation: Analysis and Implications

December 30, 2023 3285 Views 0 comment Print

Explore the latest in international taxation: from judicial precedents to regulatory changes. Dive into cases, form updates, and MFN clause implications.

Fees for Domain Registration Not Royalty under Section 9(1)(vi): Delhi HC

December 25, 2023 1281 Views 0 comment Print

Explore Delhi High Court’s landmark decision on GoDaddy’s domain registration income. Learn why court ruled against treating it as royalty under Section 9(1)(vi) of Income Tax Act.

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