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 agreement between India and Bermuda has been entered to enhance co-operation and facilitate the exchange of information with respect to administration and enforcement of the domestic laws with respect to taxes. This may result in greater transpar
Black money parked in tax havens abroad will be taxable income under the Direct Taxes Code Bill, the Centre told the Supreme Court on Wednesday, spelling out a host of measures to retrieve it. The government also informed the apex court that it has completed negotiations for Tax Informations Exchange Agreement with 10 countries where the money is believed to have been stashed.
After deciding to deploy revenue service officers at eight overseas Income Tax units, the government will now depute IRS officers at the top world economic body OECD to improve global cooperation in tackling money laundering, tax crimes and bribery.
India and Isle of Man have signed a Tax Information Exchange Agreement (TIEA) on 4th February, 2011 in London. The agreement has been signed by Shri Nalin Surie, High Commissioner of India to the United Kingdom from Indian side and Hon. Anne Craine, MHK, Minister of the Treasury from Isle of Man side. This is the second TIEA being signed by India. First TIEA was signed by India with Bermuda in Delhi on 7th October, 2010.
Union Finance Minister, Shri Pranab Mukherjee and Norwegian Minister of Research and Higher Education, Ms Tora Aasland signed an agreement, here today for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital (DTAA). This will replace the existing Convention signed between the two countries on the same subject on 31st December 1986.
The strategy adopted by the Government to tackle the menace of illicit funds is five-fold. This consists of: i) Joining Global crusade against ‘black money’; ii) Creating an appropriate legislative framework; iii) Setting up institutions for dealing
Liechtenstein has declined help in India’s quest for suspected black money trail to the small but rich European country bordering Switzerland, citing absence of a bilateral treaty for such information exchange. The Indian government is facing intens
The revised tax treaty between India and Switzerland, to enable access to Swiss accounts of tax evaders, seems to have hit bureaucratic hurdle as the two governments are yet to notify each other on the required legal and procedural approvals. As per
Reimbursable expenditure and the fee payable for technical services under DTAA between India and USA- the reimbursable expenditure received by the assessee cannot form part of the total income. – since the development of infrastructure falls within the industrial policy of Government of India specific approval may not be required for claiming exemption u/s. 10(6A) of the Act. – what was reimbursed is the service tax paid by the assessee to the Government account. therefore, such an amount cannot form part of technical fee. In other words, it cannot be treated as trading receipt. In view of the above, in our opinion, the reimbursement of service tax cannot form part of the total income of the assessee. – fee received by the assessee towards technical services / consultancy would fall under Article 12 and not under Article 7. Therefore, tax has to be levied only at 15% and not at 20%. – there is no liability to pay the advance tax wherever the tax was deducted at source. Therefore, interest was not chargeable u/s. 234B of the Act.
The ITAT held that the payments for services rendered with regard to reassembling and recommissioning of machinery in India under the Indian Tax Laws (ITL) and the India-Italy Double Taxation Avoidance Agreement (DTAA), would be excluded from fees for technical services (FTS) under the DTAA since the same were in the nature of business profits.
