Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how IRS audits are initiated and conducted to verify tax return accuracy. It highlights taxpayer duties, righ...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...
Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...
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 : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...
Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....
Income Tax : The Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
Income Tax : Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Ar...
Income Tax : ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
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...
Delhi HC ruling clarifies that KPO service providers aren’t comparable to ITES providers for benchmarking international transactions.
Delhi High Court upholds ITAT ruling in PCIT vs Global Logic India Ltd., addressing deferred payments and international transactions under Section 92B of the IT Act.
Explore the India-Mauritius DTAA’s impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fostering genuine investments.
A question that was shooting up recently, was: Why are so many Indians going to Dubai? After a detailed research and analysis I understood that there is a rush by the rich and business enterprises from different parts of the world to the United Arab Emirates (UAE) or Dubai where costly livings, advanced infrastructure as well as an outstanding location attracts.
Understand key tax provisions for non-residents in India, including residential status determination, taxable income types, and implications under Indian law.
Explore tax complexities faced by RNOR individuals in India, including foreign income taxation, DTAAs, and recent changes in tax rates impacting compliance.
The ITAT remands BorgWarner’s case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation approach used for international transactions.
Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and key judicial interpretations.
Form No. 10F is a self-declaration for NRIs to claim benefits under DTAA when their Tax Residency Certificate lacks essential details.
Introduction In International Taxation, the concept of “make available” is very important to be looked into. It helps in determining whether the concerned fee paid for the services which are rendered cross-border would be classified as royalties or fee for technical services and would attract the withholding tax. Understanding how “make available” works helps the […]
