Finance : Discover essential financial steps and tax tips for NRIs, including converting accounts, trading restrictions, and leveraging DTAA...
Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
Income Tax : Explore the details of India's Double Tax Treaty with Cyprus, its signing date, benefits for both nations, tax recovery provisions...
Income Tax : Need for early amendment of DTAA regulations to stop the double taxation of Indian IT firms: Ms. Anupriya Patel tells the visiting...
Income Tax : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...
Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...
Income Tax : ITAT Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the ...
Income Tax : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...
Income Tax : Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning depriv...
Income Tax : Understand the Ahmedabad ITAT ruling that payments for certification services by foreign entities are not taxable in India without...
Income Tax : ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal ...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
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...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
About Form 15 CA and Form 15 CB: The Income Tax Law of our country requires authentication of foreign remittances (payments) made to a Non Resident or Foreign Company, for any amount which is taxable as per the existing laws. For this purpose, certain rules and guidelines have been framed by the Income Tax Act for making foreign remittances.
The issue under consideration is whether the sale of shares by a Cyprus company to the assessee of an Indian company, who was holding a technology Park [immovable property] as only asset, is taxable in India in view of the Double Taxation Avoidance Agreement between India and Cyprus?
The issue under consideration is whether the amount paid to the employees under the non-compete agreement is covered by the expression ‘salary/profits in lieu of salary’ or not? and If not then whether the TDS will be applicable or not?
The issue of interpretation of agreements for avoidance for double taxation [AADT / DTAA / tax treaty] has always been ongoing. More particularly when it involves importing the meaning of any expressions from the interpretation adopted for any other tax treaty. India has signed tax treaties with various countries out of which certain DTAA’s (viz., […]
Recently , a ruling by AAR against Tiger Global’s claim of exemption on capital gain in the Flipkart –Walmart deal has once again brought forth the issues of treaty shopping and GAAR . Background of the ruling is narrated as follows. Investors of Flipkart included Tiger Global Management, Accel, Naspers , Softbank , Vision Fund […]
A foreign entity in Japan is appointing an sales agent in India to market and sell their products. They are not setting up an Indian entity, not hiring an employee in India but only appointing a full time agent in India. Can such a person be construed as a permanent establishment (PE) for the Japanese […]
1. Introduction to the ‘Limitation of Benefit’ Clause in Double Taxation Avoidance Agreement (DTAA): Double Taxation Avoidance Agreements (DTAAs) were developed to address the problem that arose due to international double taxation. Double taxation occurs when a certain income is taxed in two different countries resulting in the income being taxed twice. These situations generally […]
Gurgaon Investment Ltd. Vs DDIT (ITAT Mumbai) The issue under consideration is whether addition made on account of Transfer Pricing Adjustment towards interest on debentures invested in the Associated Enterprise (AE) Vital Construction Pvt. Ltd. (VCPL) is justified or not? Assessee, a non-resident company incorporated in Mauritius. Through one of its AEs based in Mauritius […]
Foreign Remittances – Fees for Technical Services-Whether a TDS is always required under Indian Income Tax Act? This article is meant to be a tool of understanding the basics of TDS on Fees for Technical Services when paid out of India. It should prove usefull for both tax professionals and also for non tax professionals/entrepreneurs […]
Technically speaking there is no concept such as International taxation. But for our convenience we say, the international aspects of income tax laws of a particular nation as international taxation.
