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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 1947 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 1104 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 2406 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 3267 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


Amount Received from US Broadcasting Company Not Taxable as “Royalty” Under India-US DTAA

September 24, 2024 336 Views 0 comment Print

Distribution revenue received by Turner Broadcasting System Asia Pacific, Inc. ( TBSAP ), a U.S.-based company, from its Indian affiliate was not taxable as “royalty” under the Income Tax Act, 1961, or the India-U.S.

Source State’s Right to Attribute Income to a PE Based on Global Income/Loss

September 21, 2024 891 Views 0 comment Print

Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.

DTAA Benefit Available on LTCG from Sale of Indian Entity Shares with Valid TRC

September 19, 2024 465 Views 0 comment Print

Assessee-company was engaged in the business of trading of electromechanical relays, wire and wireless equipment, high performance polymeric products, highly specialized energy related products, was subject to scrutiny.

Breaking Down Latest Five High Court Decisions on Income Tax Issues

September 9, 2024 2262 Views 0 comment Print

Explore five recent High Court decisions on income tax issues, including DTAA, FTS classification, MAT inclusion, reassessment orders, and reliance on external reports in tax assessments.

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

September 3, 2024 39613 Views 1 comment Print

Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications for dividends, interest, royalties and technical services.

Countrywise Withholding tax rates / Chart as per DTAA

September 3, 2024 420977 Views 28 comments Print

Withholding tax rates for dividends, interest, royalties and Fee for Technical Services in different countries. Understand how taxes vary for different recipient companies.

Payments for Online Learning Platform Access Not Taxable as FTS under India-USA DTAA

September 3, 2024 1479 Views 0 comment Print

ITAT Delhi rules Coursera’s income from Indian customers not taxable as Fees for Technical Services (FTS) under India-USA DTAA. A key decision for online platforms.

Routine support services not taxable as Fees for Technical Services in terms of India-UK DTAA: ITAT Delhi

August 30, 2024 414 Views 0 comment Print

ITAT Delhi held that routine support services would not be taxable as Fees for Technical Services (FTS) in terms of the provisions of India-UK Double Taxation Avoidance Agreement (DTAA).

Reimbursement on account of secondment of employees cannot be treated as FTS: ITAT Delhi

August 29, 2024 639 Views 0 comment Print

ITAT Delhi held that cost to cost reimbursement on account of secondment of employees cannot be treated as Fees for Technical Services (FTS) as defined under Article 12 of India USA-DTAA. Thus, appeal of the assessee allowed.

Disallowance u/s. 14A of Income Tax Act cannot exceed exempt income: ITAT Ahmedabad

August 29, 2024 435 Views 0 comment Print

ITAT Ahmedabad held that disallowance under section 14A of the Income Tax Act cannot exceed exempt income. Thus, disallowance u/s. 14A restricted to the extent of exempt income.

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