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DTAA

Latest Articles


Analysis of Impact & Effectiveness of Bilateral Investment Treaties

Income Tax : Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within ...

March 20, 2025 159 Views 0 comment Print

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 291 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 2028 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 1122 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 2712 Views 0 comment Print


Latest News


CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 789 Views 0 comment Print

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 378 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 1026 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 834 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


Latest Judiciary


No addition u/s. 28(iv) for free of cost assets from sister concern as no benefit derived

Income Tax : ITAT Bangalore held that addition under section 28(iv) of the Income Tax Act for receiving fixed assets from sister concern on fre...

March 11, 2025 360 Views 0 comment Print

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 231 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 219 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 123 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


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 3375 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 3324 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 987 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 675 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 3024 Views 0 comment Print


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

September 25, 2024 924 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 6693 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 531 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.

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

September 24, 2024 345 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 903 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 474 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 2277 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 39691 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 421592 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 1512 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.

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