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international taxation

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Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 546 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 690 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 786 Views 0 comment Print

Taxation – The Game of Life – Transfer Pricing & International Taxation

Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...

June 2, 2024 852 Views 0 comment Print

Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...

May 27, 2024 426 Views 0 comment Print


Latest News


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 198 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 67419 Views 0 comment Print

What is Filing Of 1042 Form?

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...

September 28, 2022 11595 Views 0 comment Print

UK Suspends Tax Co-Operation With Russia

Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...

March 24, 2022 399 Views 0 comment Print

ICRICT Open letter to G20 Heads of State and Government

Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...

October 12, 2021 702 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

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...

July 15, 2024 432 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

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...

July 8, 2024 267 Views 0 comment Print

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 327 Views 0 comment Print

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 345 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 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 1989 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 828 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 594 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 2298 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 4191 Views 0 comment Print


AO cannot tax Income as FTS without interpreting relevant Article of DTAA

September 5, 2023 441 Views 0 comment Print

An in-depth analysis of the ITAT Chennai’s decision on ITO vs Eshakti Com Pvt Ltd, focusing on the deletion of disallowance under section 40(a)(i) of the Income Tax Act.

Tax System followed by Different Countries

September 3, 2023 3765 Views 0 comment Print

Explore four types of income tax systems followed globally: Residence, Citizenship, Territorial, and Zero Taxation. Learn with real-life examples.

German Income Tax: Latest developments, 2023

August 26, 2023 978 Views 0 comment Print

Explore the latest developments in German Income Tax for 2023, including changes influenced by the Russia-Ukraine conflict. With the Indo-German free trade agreement looming, understanding corporate tax intricacies becomes crucial. This comprehensive guide covers aspects like Corporate Income Tax, Trade Tax, Corporate Withholding Tax, Tax Returns, and more. Stay informed about the evolving tax landscape in Germany, Europe’s largest economy, to navigate compliance and leverage potential benefits effectively.

Indonesia: A Glimpse into its Taxation System

August 17, 2023 882 Views 0 comment Print

Explore Indonesia’s unique taxation system, covering individual tax slabs, business income taxation, corporate income tax, value-added taxation, and positive developments for taxpayers. Learn about the diverse income classifications and exemptions within the Indonesian tax framework. For accurate tax compliance, verify information and consult professionals.

Technical know-how not made available- Sub-Contracting Charges Not Taxable as FIS in India

August 13, 2023 684 Views 0 comment Print

Read the analysis of SPI Global US vs ACIT (ITAT Delhi) case where sub-contracting charges taxability under India-USA DTAA was contested. Learn about the make available clause and the final decision.

UAE Corporate Tax Laws: 151 FAQs Explained

August 10, 2023 1449 Views 0 comment Print

Get comprehensive insights into UAE’s new Corporate Tax legislation through 151 FAQs. Understand regulations, exemptions, definitions, rates, and more.

Understanding Double Taxation and Relief Mechanisms

August 5, 2023 2676 Views 0 comment Print

Uncover the concept of Double Taxation, its types – Juridical and Economic, and learn about relief mechanisms such as Unilateral and Bilateral relief.

Analysis of Section 9A of Income Tax Act, 1961: Certain Activities Not to Constitute Business Connection in India

August 4, 2023 6117 Views 0 comment Print

Explore a comprehensive analysis of Section 9A of the Indian Income Tax Act, 1961. Learn how it impacts offshore funds’ business connections in India.

Global Minimum Corporate Tax (GMCT)

August 4, 2023 2937 Views 0 comment Print

Exploring the role, challenges, and impact of the OECD’s proposed Global Minimum Corporate Tax (GMCT) on India and global business.

25 FAQs on Significant Economic Presence for Non Residents Operating in India

July 27, 2023 18405 Views 0 comment Print

Explore 25 FAQs on Significant Economic Presence (SEP) for Non-Residents in India. Understand the impact of SEP on digital and e-commerce business models, reasons for its application, income tax implications, criteria, challenges, and immunity through Double Taxation Avoidance Agreements (DTAA). Stay informed about legal obligations, special roles for professionals, and the governments challenges in managing income tax leakages in the digital and e-commerce sectors. Expert insights for NRs operating in India.

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