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...
The retrospective clarificatory amendments (vide the Finance Act, 2012) do not seek to override the DTAA. In case of a conflict between the domestic law and the DTAA, DTAA will prevail, in terms of Section 90 of the Act.
The Bangladesh cabinet has approved an amendment proposal on the existing Double Taxation Avoidance Convention with India for the exchange of income tax related information.
Notification No. 7/2013 – Income Tax The Government of the Republic of India and the Government of Malaysia, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries, have agreed as follows:
We find that respondent-assessee is receiving royalty and fees for technical services rendered in India. In terms of Article 12 of DTAA, royalty and fees for technical services received in India by a person resident outside India are not liable to tax in India in excess of 10% of the gross amount received. On examination of the DTAA, we find that in terms of Article 2(3) thereof the trade tax paid in Germany is one of the taxes to which DTAA applies.
The Assessing Officer has computed the income from Bhutan operations at Rs. 68,63,57,400/- and included the same in the total income of the assessee, then the relief u/s 91 of the I T Act is allowable @ 8.53% on the said income, which is subjected to tax in both the countries. Accordingly, we direct the Assessing Officer to give relief u/s 91 by calculating the average rate of tax of 8.53% on Rs. 68,63,57,400/- subject to the total tax paid /payable in either of the countries.
The Finance Act, 2012 has inserted certain retrospective amendments in the Incomes Tax Act, 1961. One of them is insertion of explanation 4 and 5 to section 9 (1) (i) with an intent to tax transfer between nonresidents of shares of foreign company deriving value from assets located in India.
In so far as the DTAA between India and Canada is concerned, it is observed that article 12(4) thereof gives the definition of the term fees for include services while article 12(5)(a) provides that notwithstanding the said definition given in article 12(4), fees for included services does not include amount paid for services that are ancillary and subsidiary as well as inextricably and essentially linked, to the sale of property.
Government Adopts Five Pronged Strategy to bring back the black Money The Central Government has been vigorously pursuing the cases of black money stashed abroad and in bringing them back. For this purpose, a five pronged strategy has been adopted which is as follows:
Undisclosed Income of about Rs. 600 Crore Detected under DTAAs Since March 2009 and taxes of about Rs. 200 Crore Realized The Government receives information from various countries regarding assets including bank accounts held abroad by Indians under the respective Double Taxation Avoidance Agreements/Tax Information Exchange Agreements. Receipt of such information is an ongoing process.
India has entered into Double Taxation Avoidance agreements (DTAAs) with 84 countries. In addition, DTAAs have been signed with 3 countries, viz. Colombia, Uruguay & Ethiopia and will enter into force after completion of necessary formalities in these countries. Proposal to sign DTAAs with 12 more countries/jurisdictions is under process. These countries/jurisdictions are Albania, Bhutan, […]
