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Latest Articles


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

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 455018 Views 28 comments Print

Comprehensive Guide: Tax Treatment of Dividends Received

Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...

June 10, 2026 23592 Views 1 comment Print

Double Taxation Relief: Rules and Benefits in India

Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...

June 8, 2026 21240 Views 0 comment Print

Form 41 for DTAA Claims: Complete Guide under Income Tax Act 2025  

Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...

April 18, 2026 10491 Views 0 comment Print


Latest News


India–France DTAA Amended to Grant Source Country Taxing Rights on Share Capital Gains

Income Tax : India and France have signed a protocol granting full taxing rights on capital gains from share sales to the country of company re...

February 24, 2026 1440 Views 0 comment Print

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 2793 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 906 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 1938 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 1059 Views 0 comment Print


Latest Judiciary


Section 9(1)(vii) FTS Addition Set Aside; Taxability Must Be Examined Under Relevant DTAA: ITAT Delhi

Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...

July 5, 2026 408 Views 0 comment Print

ESOP Discount Allowed as Karnataka HC Precedent Covered Issue: ITAT Mumbai

Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...

June 25, 2026 150 Views 0 comment Print

Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC

Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...

June 20, 2026 114 Views 0 comment Print

Foreign Tax Credit Cannot Be Denied Merely for Delay in Filing Form 67: ITAT Pune

Income Tax : ITAT Pune held that Foreign Tax Credit cannot be denied merely because Form 67 was filed after the prescribed due date. The Tribun...

June 13, 2026 90 Views 0 comment Print

No Fixed Place PE in India as Customer Premises Were Not at Foreign Company’s Disposal: ITAT Delhi

Income Tax : The Delhi ITAT ruled that no installation or supervisory PE existed in India as the activities did not exceed the 120-day threshol...

June 13, 2026 213 Views 0 comment Print


Latest Notifications


CBDT Notifies India-Japan Tax Recovery Pact

Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...

April 2, 2026 981 Views 0 comment Print

CBDT notifies amended India-Brazil Tax Treaty

Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...

March 30, 2026 828 Views 0 comment Print

India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1275 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1797 Views 0 comment Print

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 5742 Views 0 comment Print


A discussion on Deferred tax asset and Deferred tax liability

February 7, 2019 35055 Views 1 comment Print

Background- There are differences in profit calculated by a business entity in its books and income calculated as per income tax act. We pay tax as per income calculated as per income tax act. There are 2 types of differences- 1) Permanent differences These are differences between our accounting income and taxable income that originate […]

CBDT notifies DTAA between India-Hong Kong

December 21, 2018 25071 Views 0 comment Print

Republic Of India And Government Of Hong Kong Special Administrative Region Of People’s Republic Of China For Avoidance Of Double Taxation And Prevention Of Fiscal Evasion With Respect To Taxes On Income

Entry into Force of India – Hong Kong DTAA – What does it mean

December 3, 2018 5673 Views 1 comment Print

In this article, author will discuss the implication of Hong Kong and India both completing their relevant procedures in respect to double tax avoidance agreement (DTAA). Further it will be analyzed in detail meaning of various dates in respect to India – Hong kong DTAA and date from which it can be used for remittance to Hong Kong Residents.

Protocol amending India-China DTAA

November 26, 2018 1020 Views 0 comment Print

The Government of the Republic of India and the Government of the People’s Republic of China have amended the Double Taxation Avoidance Agreement (DTAA) for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income, by signing a Protocol on 26/11/2018.

CBDT notifies protocol amending India-Portuguese DTAA

September 11, 2018 2307 Views 0 comment Print

CBDT notifies protocol amending India-Portuguese DTAA vide Notification No. 43/2018- Income Tax Dated: 11th September, 2018

Whether provisions of Section 206AA override DTAA?

August 26, 2018 17370 Views 1 comment Print

When it comes to deduction of TDS while remitting any payment to a Non-Resident the beneficial provisions of Double Taxation Avoidance Agreement (DTAA) and the Income Tax Act 1961 (Act) is applied. In case where the remittance is not taxable in India then there is no requirement to deduct TDS, otherwise TDS needs to be […]

Tax Residency Certificate (TRC) for Indian & Non Resident

August 23, 2018 300400 Views 27 comments Print

Tax Residency Certificate (TRC)  For Indian Resident Assessee From 01.4.2013 the India Residents who earns Income from Countries with which India have a DTAA can obtain  a Tax Residency Certificate from Income Tax Department. The same may be submitted to the Payer to claim DTAA Benefit.An assessee, being a resident in India, shall, for obtaining a certificate of residence for the purposes of an agreement referred to in section 90 and section 90A, make an application in Form No. 10FA to the Assessing Officer.

How to get relief in case of Double Taxation?

August 18, 2018 268953 Views 47 comments Print

In this age of globalization  many organizations including individuals have got their wings spread all over the world. In any country the tax is levied based on 1) Source Rule and 2) the Residence Rule. The source rule holds that income is to be taxed in the country in which it originates irrespective of whether the income accrues to a resident or a non-resident whereas the residence rule stipulates that the power to tax should rest with the country in which the taxpayer resides. If both rules apply simultaneously to a business entity and it were to suffer tax at both ends, the cost of operating on an international scale would become prohibitive and would deter the process of globalisation. It is from

Procedure to take Foreign Tax credit (FTC) in India

July 29, 2018 43335 Views 3 comments Print

Below Procedure to take Foreign Tax credit (FTC) in India is Governed by Rule 128 of Income Tax Rules and Applicable form 01.04.2017. a. A resident assessee will be eligible to claim FTC if any tax has been paid by him in a country or specified territory outside India. b. Grant of FTC shall be […]

Mutual Agreement between India & Qatar via exchange of letters notified

July 17, 2018 3222 Views 0 comment Print

S.O. 3468(E).— Whereas, the Agreement between the Government of the Republic of India and the Government of the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the “DTAA” )was signed on the 7th April, 1999; Whereas, clause (ii) of para 3 of Article 11 of DTTA provides for the mutual agreement for granting exemption from tax on interest derived and beneficially owned by governmental financial institutions/agencies;

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