Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
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 : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...
Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
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 : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
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 : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...
Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....
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 : 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...
This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to non-residents and foreign companies under the Income-tax Act. It serves as a comprehensive reference for AY 2026-27.
The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and residents dealing with overseas entities. It serves as a quick statutory reference for international tax compliance.
Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax Act or the applicable DTAA. The comparative chart helps identify the applicable withholding tax.
The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates differ across countries and income categories such as dividends, interest, royalties and FTS.
The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treated as an international transaction. It also directed the AO to allow set-off of brought-forward business losses and unabsorbed depreciation in accordance with law.
The article explains how India’s Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident if key decisions are made from India. It also highlights the importance of aligning management with the chosen jurisdiction.
The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement could not be taxed as its income. The Court also ruled that the APA governed the determination of the arm’s length price for the covered assessment years.
The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of international transactions. It directed inclusion and exclusion of specific comparables and partly allowed the assessee’s appeal.
The article explains how residential status under the Income-tax Act and FEMA impacts taxation, foreign income reporting, business connections, and cross-border transactions.
The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outlining TRC, Form 67, FTC limits, filing requirements, and key compliance rules.
