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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 273 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 2439 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 3273 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


Permanent Establishment in International Taxation

November 9, 2023 1584 Views 0 comment Print

Explore the intricacies of Permanent Establishment in international taxation, from UN Model to domestic laws. Learn about key provisions, tests, and recent developments. Contact us for clarity on International Taxation/DTAA.

Supreme Court’s Impact on India’s DTAA and MFN Provisions

November 8, 2023 1689 Views 0 comment Print

Explore the implications of the Indian Supreme Court’s recent judgment on Double Taxation Avoidance Agreements (DTAA) and Most Favored Nation (MFN) clauses, affecting European MNCs.

Canada Resident Eligible for India-Canada DTAA Benefit: ITAT Delhi

November 4, 2023 2118 Views 0 comment Print

ITAT Delhi rules in favor of a Canadian resident, allowing them to benefit from the India-Canada Double Taxation Avoidance Agreement (DTAA). Learn more in this article.

Comprehensive Guide: Tax Treatment of Dividends Received

November 3, 2023 13500 Views 1 comment Print

Explore dividend taxation for investors and corporations, including changes post-April 2020. Learn about domestic and foreign dividends, tax rates, and more.

Controversy surrounding Most Favoured Nation (‘MFN’) clause in DTAA

November 1, 2023 2121 Views 0 comment Print

Learn about the MFN (Most Favored Nation) Clause in Double Tax Avoidance Agreements, its recent controversy, and the Supreme Court’s clarification on its operation. Analysis and impact included.

Booking fee collected from non-resident airlines not taxable as royalty

November 1, 2023 738 Views 0 comment Print

ITAT Delhi held that the booking fee received by the assessee from non-resident airlines is taxable as ‘business income’ and not as ‘royalty’ u/s. 9(1)(vi) of the Income Tax Act and Article 13(3) of Indo-Spain DTAA.

Income Tax Agreement Between India & Saint Vincent for information Exchange

November 1, 2023 660 Views 0 comment Print

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

Sale of software not containing any element of service not fall under FTS

October 31, 2023 1197 Views 0 comment Print

In the SoftwareONE Pte. Ltd. vs. ACIT case, the ITAT Delhi ruled that sales of software without any service component are not liable to be taxed as Fees for Technical Services (FTS) under the India-Singapore DTAA.

Relief under Section 90 and Form 67 in Indian Income Tax: A Guide and Consideration for Belated Filing

October 28, 2023 4830 Views 0 comment Print

Explore Indian Income Tax Section 90 & Form 67 for foreign tax relief. Learn about belated filing, rules, and ITAT judgments. Expert insights and guidance.

Double Taxation Relief: Rules and Benefits in India

October 27, 2023 17520 Views 0 comment Print

Double taxation can be a concern when a person residing in India earns income that is also taxable in a foreign country. To address this issue, individuals can claim credit for taxes paid outside India as Foreign Tax Credit (FTC)

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