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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 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


Determination of taxability of a Non-Resident Individual in India

April 26, 2023 3684 Views 0 comment Print

Explore the determination of taxability for Non-Resident Individuals (NRIs) in India. Understand the steps involving residential status identification, tax incidence, and the choice between existing and new tax regimes. Learn about TDS, tax liability calculation, and the impact of Double Taxation Avoidance Agreements (DTAA) on NRIs. Get insights into the technical aspects of income taxation for NRIs under the Income Tax Act 1961.

No Denial of FTC for non-filing of Form No. 67

April 23, 2023 1158 Views 0 comment Print

Filing of Form No. 67 under Rules 128 of Income Tax Rules is a procedural requirement, therefore, is a directory in nature, non-compliance thereof does not disentitled assessee in claiming Foreign Tax Credit (FTC)

Lease rental from associated enterprises is not royalty – India-USA DTAA

April 15, 2023 1200 Views 0 comment Print

ITAT held that lease rental received by assessee on leasing of alloys cannot be treated as royalty in terms of India-USA DTAA & provisions of section 9(1)(vi)

Is my Income Earned Abroad is Taxable?

April 14, 2023 1080 Views 0 comment Print

NRI taxation under the Indian Income Tax Act, of 1961 applies to those earning income outside the home country. The income tax rules and perks allowed to them are drastically different from those applicable to resident Indians.

G-20 Taxation – United Kingdom (UK)

April 13, 2023 894 Views 0 comment Print

Explore the intricacies of the United Kingdoms tax system, vital for education, jobs, and immigration. Learn about income tax, capital gains tax, private residence relief, marriage allowance, and more. Stay informed about tax rates, bands, and business-related tax in the UK. Source: UK Government Website, Tax Regulations, G-20 Taxation Updates.

Thinking of Investing in US Stocks from India? Brace Yourself with the Taxing Truth

April 12, 2023 8184 Views 1 comment Print

Uncover the taxing truth of investing in US stocks from India. Navigate the complexities of Indian and US tax systems, understand implications on dividends and capital gains, and learn to minimize tax liabilities. CA Mridul Gupta, a practicing Chartered Accountant, breaks down the intricacies to guide investors through informed decision-making. Brace yourself for the taxing reality of investing in the colossal US stock market from the comfort of your home in India.

Non-Filing of Form No. 67 Is Merely A Procedural Error & Foreign Tax Credit Can’t Be Denied

April 12, 2023 5622 Views 0 comment Print

Assessee filed ROI claiming relief u/s 90 but did not file Form No.67. Form was subsequently filed beyond the due date as per under Rule. CPC did not give credit for foreign tax.

Tax rate on Non-resident in India for FTS & Royalty services doubled from 01.04.2023

April 11, 2023 40698 Views 5 comments Print

As of April 1, 2023, India has doubled tax rates for non-residents on Fees for Technical Services (FTS) and Royalty to 20%. Explore the impact, mandatory filings, and potential defenses against these changes.

UAE Small Business Relief- A Deep Dive

April 10, 2023 2355 Views 0 comment Print

Small Business Relief is intended to support start-ups and other small or micro businesses by reducing their Corporate Tax burden and compliance costs. The Ministerial Decision on Small Business Relief specifies the revenue threshold and conditions for a taxable person to elect for Small Business Relief and clarifies the provisions of the carried forward Tax Losses and disallowed Net Interest Expenditure under the Small Business Relief scheme.

G-20 Taxation – Japan

April 8, 2023 1365 Views 0 comment Print

Due to initiation of Japanese taxation in my earlier articles, let me narrate the steps taken by Jetro, Japan external trade organization (web page with official tax information), and National Tax Agency to update our knowledge for the tax year 2022, particularly in view of G 20 Taxation compilation merging with Indian presidentship of the same.

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