Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...
Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
Income Tax : Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement ...
Income Tax : Forms 1042, 1042-S, and 1042-T are U.S I.R.S taxation forms dealing with dealings with foreign persons, including non-resident ali...
Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...
Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...
Income Tax : On 3rd October, 2021, the International Consortium of International Journalists (ICIJ) has come out with what is claimed to be a 2...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...
Income Tax : In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren't taxable in India...
Income Tax : In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren't considered FTS under ...
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...
Understand the UAE’s transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure compliance with Article 36 requirements.
Explore the ITAT Hyderabad’s decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed analysis and conclusions provided.
Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under India-Thailand DTAA, absence of FTS clause, and PE considerations.
Delhi High Court quashes reassessment notices by DCIT after TPO settles arm’s length remuneration issue. Detailed analysis of Progress Rail Locomotive Inc. vs DCIT case.
Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping tax treaties.
In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren’t taxable in India as royalty or FTS under the Income-tax Act or India-Singapore DTAA.
Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associated enterprises, specified domestic transactions, and the methods for determining arm’s length prices.
Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Undertaxed Profits Rules, and their impact on corporate restructuring.
In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren’t considered FTS under India-Netherlands DTAA.
Issuance Of Letters Of Comfort/Support will Construe As International Transaction U/s 92B considering corporate guarantee issued by assessee could not be compared with the letters of comfort and therefore agreed with the computation of arm’s length rate of 0.04%.
