Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...
Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...
Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...
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...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
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 : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
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...
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...
Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...
Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
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, […]
On the request of the Central Government and persistent follow up in June, 2011, France has provided details of Indians having bank accounts in one of the banks of Switzerland under the provisions of Double Taxation Avoidance Convention (DTAC) between India and France. Based on this information, investigations have been undertaken by the different jurisdictional authorities under the Income Tax Act, 1961.
Information received from the Government of France has been analysed and investigations into the information have been undertaken by the different jurisdictional authorities under the Income-tax Act, 1961. Investigations in the matter are under progress including with the foreign tax authorities to obtain more information with regard to the reported account holders.
Desiring to amend the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains signed at New Delhi on 25 January 1993 (hereinafter referred to as the Convention),
Protocol Amending the Convention between India, UK and the Northern Ireland Signed for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains
