international taxation

Determination of Residential Status of Individual under Income Tax Act

Income Tax - Introduction: Determination of the residential status under Income Tax Act plays a vital role in to determine whether a person comes under the tax net or not. Section 6 of the Income Tax Act deals about the concept of resident for Income tax purposes. Finance Act 2020 dated 23.03.2020 amends Section 6 of the Income […]...

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Japan Income Tax, 2019 – New Revelations

Income Tax - Japan is in the process of shifting its goal post for Olympic Games 2020 to 2021. But its income tax details for 2019 are already out and helping millions to understand, and implement by filing tax returns at point of need. Yes, let us understand Japan Income Tax, 2019 in details for a common man. […]...

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U S Taxation, 2019: Individual tax – Form 1040, line 9, Itemized deductions

Income Tax - Nothing satiates my heart than when some- one paying American tax for the tax year 2019, enquires about technical questions about its preparation. Yes, believe me some one telephoned and held detailed discussions on item No. 9 on Form 1040, intended for an individual tax. Line No. 9 popularly called as “Itemized deductions” has been [...

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Income Tax on Non Resident Indians (NRI)

Income Tax - Many Individuals from India have settled abroad. Moving to another country does not necessarily mean Good-Bye to the Home Country India. Many NRIs have invested in India in the form of Purchase of Mutual Funds, Life Insurance Policies, Shares, Securities, ancestral land/property, Unit Linked Insurance Plans (ULIPs), FCNR Fixed Deposit, ho...

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US Taxation for 2019; Forms 1040-SR, 1040 and more

Income Tax - One of my senior clients telephoned about his tax return of USA for 2019 but with emphasis on 1040 SR. I was not taken aback since for one well versed with US Taxation, change is spice of life. We as CPAs are forced to update our knowledge by CPE stipulations.  I am very happy to […]...

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Income tax Authority before whom particulars of parent entity and alternate reporting entity to file CbC Report

Income Tax - Income Tax Department designates Income tax Authority before whom particulars of parent entity and alternate reporting entity to file Country-by-Country Report would be notified...

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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 modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of th...

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CBDT releases MLI synthesised text for India-Poland tax treaty

Income Tax - CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND ...

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CBDT releases MLI synthesised text for India-Australia tax treaty

Income Tax - CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT  OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN ...

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CBDT releases MLI synthesised text for India-Singapore tax treaty

Income Tax - CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNME...

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Static vs. Ambulatory interpretation of DTAAs – Retrospective amendments to definition of royalty

ACIT Vs Reliance Jio Infocomm Ltd. (ITAT Mumbai) - ACIT Vs Reliance Jio Infocomm Ltd. (ITAT Mumbai) Let us appreciate the nature of development, from the treaty perspective, in case one is to hold that the retrospective amendments defining the expression ‘process’ would be equally applicable for definition of ‘royalties’ under the tax treaty...

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Satellite transmission services provided by USA based company in India cannot be taxed as Royalty

Intelsat Corporation Vs DCIT (ITAT Delhi) - ITAT held that Satellite transmission services provided by USA based company in India could not be brought to tax by treating the same as royalty income and amendment to the Income Tax Act, 1961 with a retrospective or prospective effect, cannot be read in a manner so as to extend the operation to t...

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Retrospective amendment in section 9(1)(vi) cannot override India-Ireland DTAA

Ixia Technologies International Ltd. Vs ACIT(IT) (ITAT Kolkata) - Ixia Technologies International Ltd. Vs ACIT(IT) (ITAT Kolkata) Since assessee`s case is covered by beneficial provisions of the India-Ireland DTAA, hence the retrospective amendment made in the provisions of section 9(1)(vi) of the Act, which provides that royalty would include consideration for tr...

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Amount paid to Foreign Lawyer to represent in Foreign Court was legal fees not FTS

ONGC as representative assessee of Dewey & Le Boeuf International Company LLC Vs DCIT (International Taxation) (ITAT Delhi) - Amount paid to foreign lawyer by assessee for representing its case before foreign court was not taxable as fees for technical services (FTS) in India as legal services could not be treated as FTS as it was a professional services which was outside the scope of Section 9(1)(vii)....

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DTAA cannot be overridden by a unilateral legislative amendment by one Country

CIT (IT)­ Vs Reliance Infocomm Ltd (Bombay High Court) - Mere amendments in the Act would not over­ride the provisions of Double Tax Avoidance Agreement (DTAA). It was held that: on a final note, India’s change in position to the OECD Commentary cannot be a fact that influences the interpretation of the words defining royalty as they stand today....

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Agreement between India & Brunei for Exchange of Information notified

NA - (17/03/2020) - The Agreement between the Government of the Republic of India and the Government of Brunei Darussalam for the exchange of information and assistance in collection with respect of taxes (hereinafter referred to as the Agreement), was signed in New Delhi, India on 28th of February, 2019. The Agreement...

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Cabinet approves amendment in DTAA with Sri Lanka

NA - (12/02/2020) - Press Information Bureau Government of India Cabinet 12-February-2020 Cabinet approves protocol amending the Agreement between India and Sri Lanka for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income The Union Cabinet, chaired by the Prime Minister Sh...

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CBDT notifies Revised India -China DTAA Protocol

Notification No. 54/2019-Income Tax [S.O. 2562(E)] - (17/07/2019) - Protocol amending the Agreement between the Government of the Republic of India and the Government of the People’s Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and the Protocol thereto Signed at New Delhi on 18th July, ...

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India ratifies Multilateral Convention to Prevent BEPS

NA - (02/07/2019) - India has ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which was signed by the Hon’ble Finance Minister at Paris on 7th June, 2017 on behalf of India, alongwith representatives of more than 65 countries....

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Agreement for exchange of information with Marshall Islands notified

Notification No. 40/2019 [S.O. 1789(E).] - (21/05/2019) - Government of the Republic of India and the Government of Republic of the Marshall Islands, desiring to facilitate the exchange of information with respect to taxes have agreed as follows:...

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Recent Posts in "international taxation"

Determination of Residential Status of Individual under Income Tax Act

Introduction: Determination of the residential status under Income Tax Act plays a vital role in to determine whether a person comes under the tax net or not. Section 6 of the Income Tax Act deals about the concept of resident for Income tax purposes. Finance Act 2020 dated 23.03.2020 amends Section 6 of the Income […]...

Read More
Posted Under: Income Tax |

Japan Income Tax, 2019 – New Revelations

Japan is in the process of shifting its goal post for Olympic Games 2020 to 2021. But its income tax details for 2019 are already out and helping millions to understand, and implement by filing tax returns at point of need. Yes, let us understand Japan Income Tax, 2019 in details for a common man. […]...

Read More
Posted Under: Income Tax |

U S Taxation, 2019: Individual tax – Form 1040, line 9, Itemized deductions

Nothing satiates my heart than when some- one paying American tax for the tax year 2019, enquires about technical questions about its preparation. Yes, believe me some one telephoned and held detailed discussions on item No. 9 on Form 1040, intended for an individual tax. Line No. 9 popularly called as “Itemized deductions” has been [...

Read More
Posted Under: Income Tax |

Income Tax on Non Resident Indians (NRI)

Many Individuals from India have settled abroad. Moving to another country does not necessarily mean Good-Bye to the Home Country India. Many NRIs have invested in India in the form of Purchase of Mutual Funds, Life Insurance Policies, Shares, Securities, ancestral land/property, Unit Linked Insurance Plans (ULIPs), FCNR Fixed Deposit, ho...

Read More
Posted Under: Income Tax |

US Taxation for 2019; Forms 1040-SR, 1040 and more

One of my senior clients telephoned about his tax return of USA for 2019 but with emphasis on 1040 SR. I was not taken aback since for one well versed with US Taxation, change is spice of life. We as CPAs are forced to update our knowledge by CPE stipulations.  I am very happy to […]...

Read More
Posted Under: Income Tax |

Income tax Authority before whom particulars of parent entity and alternate reporting entity to file CbC Report

Income Tax Department designates Income tax Authority before whom particulars of parent entity and alternate reporting entity to file Country-by-Country Report would be notified...

Read More
Posted Under: Income Tax |

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of th...

Read More
Posted Under: Income Tax |

CBDT releases MLI synthesised text for India-Poland tax treaty

CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND ...

Read More
Posted Under: Income Tax |

CBDT releases MLI synthesised text for India-Australia tax treaty

CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT  OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN ...

Read More
Posted Under: Income Tax |

CBDT releases MLI synthesised text for India-Singapore tax treaty

CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNME...

Read More
Posted Under: Income Tax |

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