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international taxation

Latest Articles


Global Tax Avoidance: Double Irish, Dutch Sandwich

Income Tax : Explore how MNCs used the Double Irish & Dutch Sandwich strategy to avoid taxes and the global efforts made to close these loophol...

April 15, 2025 474 Views 0 comment Print

Analysis of Impact & Effectiveness of Bilateral Investment Treaties

Income Tax : Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within ...

March 20, 2025 423 Views 0 comment Print

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 321 Views 0 comment Print

USA Taxation, 2024: Updated guidelines for Corporates

Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...

February 24, 2025 1113 Views 0 comment Print

Delhi High Court Rules on Technical Services in International Logistics

Income Tax : CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a si...

February 21, 2025 324 Views 0 comment Print


Latest News


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 1329 Views 0 comment Print

CRS & FATCA: Tax Transparency & Disclosure of Foreign Assets & Income

Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...

January 3, 2025 978 Views 0 comment Print

Budget 2024: New Rules for Including Foreign Taxes in Total Income

Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...

July 24, 2024 858 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 408 Views 0 comment Print

Format of Declaration of no PE in India and Form No. 10F

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 ...

May 8, 2023 93126 Views 0 comment Print


Latest Judiciary


Planning, HR, Legal & IT Support Not Taxable as FTS Under India-USA DTAA, Citing ‘Make Available’ Test

Income Tax : ITAT Delhi rules Crocs Inc.'s service income not taxable in India under DTAA, as services did not "make available" technical knowl...

April 20, 2025 276 Views 0 comment Print

Receipts from Passenger System Solutions not taxable as FTS in India: ITAT Mumbai

Income Tax : ITAT Mumbai rules Sita USA's airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2...

April 15, 2025 180 Views 0 comment Print

Capital Gains on Mutual Funds by Singapore Resident Not Taxable in India: ITAT Mumbai

Income Tax : ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore ...

April 15, 2025 1359 Views 0 comment Print

Capital Gains on Mutual Fund Units Not Taxable in India for Singapore Resident Under DTAA: ITAT Mumbai

Income Tax : ITAT Mumbai allows tax exemption on capital gains for NRI under India-Singapore DTAA, rejecting AO's classification of mutual fund...

April 4, 2025 1281 Views 0 comment Print

Reimbursement of Salaries to Seconded Employees Does Not Constitute FTS

Corporate Law : Karnataka HC upholds Flipkart's stance on TDS under Section 195, ruling seconded employees' salaries as reimbursements, not taxabl...

March 16, 2025 1029 Views 0 comment Print


Latest Notifications


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 3402 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 1017 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 699 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 3075 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4758 Views 0 comment Print


Latest Posts in international taxation

Planning, HR, Legal & IT Support Not Taxable as FTS Under India-USA DTAA, Citing ‘Make Available’ Test

April 20, 2025 276 Views 0 comment Print

ITAT Delhi rules Crocs Inc.’s service income not taxable in India under DTAA, as services did not “make available” technical knowledge to Crocs India.

Receipts from Passenger System Solutions not taxable as FTS in India: ITAT Mumbai

April 15, 2025 180 Views 0 comment Print

ITAT Mumbai rules Sita USA’s airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2021-22 dismissed.

Capital Gains on Mutual Funds by Singapore Resident Not Taxable in India: ITAT Mumbai

April 15, 2025 1359 Views 0 comment Print

ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore DTAA.

Global Tax Avoidance: Double Irish, Dutch Sandwich

April 15, 2025 474 Views 0 comment Print

Explore how MNCs used the Double Irish & Dutch Sandwich strategy to avoid taxes and the global efforts made to close these loopholes with a 15% minimum tax rate.

Capital Gains on Mutual Fund Units Not Taxable in India for Singapore Resident Under DTAA: ITAT Mumbai

April 4, 2025 1281 Views 0 comment Print

ITAT Mumbai allows tax exemption on capital gains for NRI under India-Singapore DTAA, rejecting AO’s classification of mutual fund units as taxable shares.

Analysis of Impact & Effectiveness of Bilateral Investment Treaties

March 20, 2025 423 Views 0 comment Print

Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within Indian context but referring to general international experiences.

CBDT Clarifies Guidance on Principal Purpose Test (PPT)

March 17, 2025 1329 Views 0 comment Print

CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not affect other tax provisions.

Reimbursement of Salaries to Seconded Employees Does Not Constitute FTS

March 16, 2025 1029 Views 0 comment Print

Karnataka HC upholds Flipkart’s stance on TDS under Section 195, ruling seconded employees’ salaries as reimbursements, not taxable income for Walmart Inc.

Switzerland Suspends Unilateral MFN Clause Application in Tax Treaty with India

March 4, 2025 321 Views 0 comment Print

Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Supreme Court’s 2023 ruling.

Mere operational links or subsidiary relationships do not confer PE status: Delhi HC

February 24, 2025 633 Views 0 comment Print

Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software revenue, interest income & vendor financing.

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