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DTAA

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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 2412 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


Receipt from hotel owners for providing various centralized services cannot be treated as FIS

March 22, 2024 279 Views 0 comment Print

ITAT Delhi held that revenue received from various hotel owners for providing various centralized services cannot be treated as fees for included services (FIS) either under Article 12(4)(a) or 12(4)(b) of the India-US tax treaty. Thus, in absence of PE in India, the same is not taxable.

Taxpayer possessing Tax Residency Certificate Eligible for DTAA Benefit: Kolkata ITAT

March 20, 2024 498 Views 0 comment Print

Debarghya Chattopadhaya vs DCIT – Kolkata ITAT rules taxpayer, possessing tax residency certificate and taxed in another contracting state, deserves treaty benefit u/s 90. Full analysis here.

Interconnect Usage Charges Not Taxable as Royalty: ITAT Bangalore

March 19, 2024 312 Views 0 comment Print

HCG Global Communications Ltd. vs. DCIT (ITAT Bangalore) case ruling: Telecom interconnect usage payments received by a foreign company from an Indian operator deemed non-taxable as ‘royalty’ under the Income Tax Act.

CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

March 19, 2024 3309 Views 0 comment Print

Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and changes in taxation laws.

Key Provisions and Implications of India-USA Tax Treaty

March 18, 2024 10356 Views 1 comment Print

Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxation of incomes, and DTAA benefits.

Foreign Tax Credit (FTC): Importance, Concept and How to Claim FTC

March 18, 2024 3051 Views 0 comment Print

Understanding Foreign Tax Credit (FTC) in India: Learn its significance, rules, claiming procedure, case law insights, and steps to avoid double taxation effectively.

Technical service in section 9(1)(vii) denote services catering to special needs and not facility provided to all: Delhi HC

March 18, 2024 732 Views 0 comment Print

Delhi High Court held that use of facility does not amount to technical services, as technical services in section 9(1)(vii) of the Income Tax Act denote services catering to the special needs of the person using them and not a facility provided to all. Thus, order denying NIL/ lower TDS certificate quashed as services provided doesn’t amount to technical service.

Liaison Office having active role treated as Permanent Establishment in terms of Article 5(2) of India-Germany DTAA

March 8, 2024 552 Views 0 comment Print

ITAT Delhi held that Liaison Office playing an active role with regard to printing of books treatable as Permanent Establishment in terms of Article 5(2) of India-Germany Double Taxation Avoidance Agreement (DTAA).

All about Form 10F and its Filing Procedure

March 5, 2024 14814 Views 3 comments Print

Learn the essentials of Form 10F filing for non-residents seeking DTAA benefits in India, including required documents, filing process, and online submission.

Receipts from Software Sale to Indian Entities Not Taxable under India-Singapore DTAA: ITAT Delhi

March 4, 2024 807 Views 0 comment Print

Detailed analysis of Finastra International Financial Systems PTE Ltd. Vs ACIT(International Taxation) case where ITAT Delhi ruled that software sales to Indian entities are not taxable under Article 12(3) of India-Singapore DTAA.

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