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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


AO cannot reject TRC without providing relevant information to petitioner

June 30, 2023 690 Views 0 comment Print

Delhi High Court scrutinizes the validity of Tax Residency Certificate (TRC) held by Vodafone Mauritius in their tax litigation case against ACIT Circle International Tax.

ITAT Ruling: Taxation of Software Sales and Royalty Payments

June 29, 2023 828 Views 0 comment Print

Analyze the case of DCIT vs. Software One Pte Ltd. (ITAT Delhi) regarding the taxation of software sales and royalty. Understand the distinction between copyright ownership and distribution rights, as well as the impact of the Supreme Court’s decision in the Engineering Analysis case.

Income Tax Provisions applicable to non-residents

June 29, 2023 59254 Views 6 comments Print

Every year the residential status of the taxpayer is to be determined by applying the provisions of the Income-tax Law designed in this regard (discussed later) and, hence, it may so happen that in one year the individual would be a resident and ordinarily resident and in the next year he may become

21 FAQs on Taxation Laws for Foreign Corporate + NRIs + NRs in India

June 22, 2023 3459 Views 1 comment Print

Explore 21 FAQs on Taxation Laws for Foreign Corporates, NRIs, and NRs in India. Understand the intricate regulations governing businesses, investments, and technology exchanges. Learn about Indian government initiatives to create favorable tax policies, stimulate growth opportunities, and reduce uncertainties. Delve into concepts like Place of Effective Management (POEM) and Significant Economic Presence (SEP).

South Africa’s 2023 Tax Filing Season Insights

June 21, 2023 738 Views 0 comment Print

Gain insights into South Africa’s taxation system for the 2023 filing season. Understand individual income tax rates, the process of registration with the South African Revenue Service (SARS), and updates for the upcoming season. Explore the nuances of multiple income sources, unique registration methods, and the impact on economic development. Stay informed about key dates and changes in the taxation landscape.

Unraveling the Mysteries of Royalties and Fees for Technical Services in India

June 13, 2023 15006 Views 0 comment Print

Classification of royalties and fees for technical services as income in India according to the Income-tax Act, 1961. Explore the definitions and implications of these categories, as well as the concept of Tax Deducted at Source (TDS) and its rates for residents and non-residents.

16 FAQ’s on FATCA Non-Tax Treaty (Agreement) between India and USA

June 8, 2023 3990 Views 0 comment Print

Learn about the Foreign Account Tax Compliance Act (FATCA) non-tax treaty between India and the United States, its implications on reporting foreign assets, and taxation of investments in India by US tax residents. Understand the complexities of FATCA regulations and the need for expert advice.

U.S. Corporations Owned by Foreign/ Indian Shareholders – Comprehensive Tax Implications and Reporting Requirements

June 6, 2023 726 Views 0 comment Print

Unlock the complexities of tax implications and reporting requirements for U.S. corporations owned by foreign entities, especially Indian shareholders. Dive into withholding taxes, branch profits tax, CFC rules, and reporting obligations, ensuring compliance and optimizing tax outcomes.

G 20 Taxation – European Union – BEPS, 2023

May 18, 2023 963 Views 0 comment Print

Explore G20 Taxation, European Unions efforts against tax avoidance, and the impact of BEPS in 2023. Understand the latest global tax initiatives, including the OECD/G20 Inclusive Framework on BEPS, and how multinational enterprises are subject to a 15% effective minimum tax rate. Stay informed about the Pillar Two GloBE Rules, Safe Harbours, Penalty Relief, GloBE Information Return, and Tax Certainty.

Foreign tax credit against form 67 filed before completion of assessment is duly allowable

May 10, 2023 2775 Views 0 comment Print

ITAT Mumbai held that foreign tax credit duly available even if form no. 67 is filed along with the revised return as the form is filed before the completion of the assessment.

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