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international taxation

Latest Articles


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 67422 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 435 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


Benefit to Non-Residents under Income Tax Act, 1961

July 25, 2023 108672 Views 0 comment Print

Articles explain who is Non-Resident Individual, Partnership firm, Company for Income Tax Purpose, Taxable Income of Non Residents, Tax on Indirect transfer of a capital asset situated in India by Non-Residents, activities not to constitute business connection in India, Exemption from applicability of Section 206AA to non-residents

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

July 24, 2023 37360 Views 1 comment Print

Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications for dividends, interest, royalties and technical services.

​International Business- Income Tax Sections to be remembered

July 24, 2023 15533 Views 1 comment Print

Relevant provisions of Indian Income Tax Act that non-residents must comply with when setting up a business in India, and residents dealing with non-residents.

Countrywise Withholding tax rates / Chart as per DTAA

July 24, 2023 398447 Views 28 comments Print

Withholding tax rates for dividends, interest, royalties and Fee for Technical Services in different countries. Understand how taxes vary for different recipient companies.

Taxation of Expats in India: Residence-Based System & DTAA Explained

July 24, 2023 1710 Views 0 comment Print

Get insights into the tax obligations of expats in India, the residence-based taxation system, and Double Taxation Avoidance Agreements (DTAA). Understand tax deductions, compliance, and the GST impact on expats’ income.

ITAT Allows Foreign Tax Credit for Taxable Employment Bonus

July 22, 2023 522 Views 0 comment Print

Explore the critical decision in Souvik Mukherjee Vs ITO (ITAT Delhi) regarding taxation of a bonus received abroad, and how it impacts Foreign Tax Credit regulations.

Applicability of POEM on Foreign Company in India

July 20, 2023 13491 Views 0 comment Print

Get answers to 41 frequently asked questions about the POEM (Place of Effective Management) concept for companies located outside India but controlled from India. Understand the implications, criteria, and international perspectives on POEM.

Mere passport insufficient to confirm assessee’s US tax residency

July 14, 2023 684 Views 0 comment Print

An in-depth analysis of the case Parag Bhikhubhai Patel vs ITO, exploring implications of using passports to confirm US tax residency for NRIs under India-USA Tax Treaty

India’s Drive for Tax Transparency and Balanced Treaty Negotiations

July 13, 2023 744 Views 0 comment Print

Discover how India is adhering to global tax standards and enhancing its treaty network. Explore the steps taken, challenges faced, and opportunities available in India’s drive for tax transparency and fair treaty negotiations.

Understanding Form 15CA and Form 15CB: A Comprehensive Guide

July 4, 2023 6141 Views 0 comment Print

In this article, we provide a detailed analysis of Form 15CA and Form 15CB, their purpose, when they are required, and how to file them. Discover the mandatory information needed for filing and the transactions exempt from Form 15CA. Read on to ensure compliance with tax regulations for remittances to non-residents.

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