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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


Understanding Tax Implications for Foreign (Indian) Individuals Owning a single member LLC in the USA

May 9, 2023 3624 Views 0 comment Print

United States is a highly attractive destination for foreign investors due to its stable economy and business-friendly environment. Many foreign individuals choose to establish Limited Liability Companies (LLCs) in the USA to take advantage of the numerous benefits it offers.

Format of Declaration of no PE in India and Form No. 10F

May 8, 2023 67422 Views 0 comment Print

Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement referred to in section 90 and 90A i.e. (for claiming the benefit of DTAA – Double Tax Avoidance Treaties) To, _____________________ _____________________ Declaration : No PE in India Sir, The Following letter is […]

Without remote link between activities of other projects with PE, Force of Attraction Rule not apply

May 4, 2023 690 Views 0 comment Print

ITAT Delhi held that the Force of Attraction Rule doesn’t apply unless there is even a remote link between the activities of other projects is established with the PE.

DTAA between India and Chile notified by CBDT

May 3, 2023 2298 Views 0 comment Print

Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Protocol between the Government of the Republic of India and the Government of the Republic of Chile for the Elimination of Double Taxation and the Prevention of Fiscal Evasion and Avoidance with respect to taxes on […]

Form 10F – Electronic Filling/Manual Filling – Analysis

May 3, 2023 13248 Views 0 comment Print

Form 10F is required to be file by a non-resident taxpayer with income tax department India as per section 90(5) and section 90A (5) of income tax act 1961, to claim the relief under applicable double taxation avoidance agreement.

ITAT allows Foreign Tax Credit as ITR & Form 67 filed within extended due date

May 3, 2023 1785 Views 0 comment Print

Foreign Tax Credit allowable as assessee filed return of income & statement in Form-67 within due dates as extended by Finance Ministry

G-20 Taxation – Mexico

May 1, 2023 810 Views 0 comment Print

Explore the intricate taxation system of Mexico and its impact on Indias trade relations. Learn about resident and non-resident tax rates, corporate tax, VAT, and recent reforms. Stay informed for successful cross-border trade.

Basic Concept and Provision Relevant to Taxability of Non-Resident

April 28, 2023 2169 Views 0 comment Print

Income Tax Act has contained various provisions relevant to Non-Resident person depend upon its residential status, Scope of Income, business connection or permanent establishment in India etc.

Income Deemed to Accrue/Arise in India for Non-Resident

April 28, 2023 3060 Views 0 comment Print

Understand the complexities of income deemed to accrue arise in India for non-residents. Learn about taxability on business connections, property, salary, interest, dividends, royalties, and fees for technical services. Stay informed to navigate taxation rules effectively.

Subscription Fee Received by American Chemical Society cannot be Treated as Royalty

April 28, 2023 534 Views 0 comment Print

Subscription revenue received by assessee in Chemical Extract Service and Publication division does not qualify as ‘Royalty’ in terms of section 9(1)(vi) of the Act & Article–12(3) of India–USA DTAA.

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