Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
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 : 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 : 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 : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...
Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
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 : 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...
Delhi HC ruled on appeal in PCIT vs Global Logic India Ltd, upholding exclusion of comparables due to absence of segmental info & treatment of foreign exchange gain/loss as operating income/operating loss
Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital
Delhi High Court upholds ITAT’s decision: Advertising, Marketing, and Promotion (AMP) expenses by Wrigley India Pvt. Ltd. not considered an international transaction.
Delhi High Court rules on income tax and administrative services provided by a Singapore entity to its Indian affiliate. Analysis of the case Commissioner of Income Tax vs. Bio-Rad Laboratories.
Explore the intricacies of Permanent Establishment in international taxation, from UN Model to domestic laws. Learn about key provisions, tests, and recent developments. Contact us for clarity on International Taxation/DTAA.
Explore the implications of the Indian Supreme Court’s recent judgment on Double Taxation Avoidance Agreements (DTAA) and Most Favored Nation (MFN) clauses, affecting European MNCs.
ITAT Delhi rules in favor of a Canadian resident, allowing them to benefit from the India-Canada Double Taxation Avoidance Agreement (DTAA). Learn more in this article.
Learn about the MFN (Most Favored Nation) Clause in Double Tax Avoidance Agreements, its recent controversy, and the Supreme Court’s clarification on its operation. Analysis and impact included.
Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and assistance. Analysis & impact.
In the SoftwareONE Pte. Ltd. vs. ACIT case, the ITAT Delhi ruled that sales of software without any service component are not liable to be taxed as Fees for Technical Services (FTS) under the India-Singapore DTAA.
