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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


Drop shipping businesses in USA & Indian Tax Residents Tax implications

April 4, 2023 4086 Views 0 comment Print

Discover the tax implications for dropshipping businesses in the USA and India. Learn about entity types, income tax, international tax forms, Indian laws, and tax treaties to navigate the complexities and ensure compliance while maximizing profits.

Mere usage of name of Foreign AE not convert a transaction into international transaction

April 3, 2023 1005 Views 0 comment Print

Philips India Ltd. vs ACIT (ITAT Kolkata) In many cases, licensed manufacturers operate as risk-bearing entrepreneurs, and there is no existence of an ‘agreement’ or ‘arrangement’ or ‘understanding’ with the AE regarding AMP expenditure, the initial onus is on the revenue to show that there is an international transaction for AMP spend. The mere fact […]

Payment by Google India to Google Ireland is not Royalty/ FTS hence TDS not deductible

April 3, 2023 1542 Views 0 comment Print

ITAT Bangalore held that that the payment made by GIPL (Google India Pvt. Ltd.) to GIL (Google Ireland Limited) is not in the nature of Royalty or FTS under the Act. Accordingly, TDS under section 195 of the Income Tax Act not deductible.

G 20 Taxation – Australia

April 1, 2023 1227 Views 0 comment Print

“Explore the intricacies of Australias tax system, covering topics from TFN to tax rates, deductions, capital gains tax, and insights on crypto assets. Stay informed about business tax rates, concessions, and the process for not-for-profit organizations. Gain valuable knowledge for Indians engaging in trade or business with Australia.”

Decoding UAE Corporate Tax Law: Comprehensive Analysis

March 31, 2023 3867 Views 0 comment Print

Explore the comprehensive analysis of UAE Corporate Tax Law, article by article. Understand definitions, imposition rates, exemptions, taxable persons, and more for effective compliance.

Iceland Taxation from emerging economies

March 31, 2023 996 Views 0 comment Print

Explore the tax implications of doing business with Iceland, a country with a stable democracy and a thriving economy. Understand the tax brackets, benefits for foreign experts, and the process for importing and exporting goods. Learn about Iceland’s tax equality policy and penalties for non-compliance. Discover the potential for Indian businesses in this emerging market and how to navigate tax regulations for successful ventures.

PoEM: Place of Effective Management

March 29, 2023 28926 Views 0 comment Print

Place of Effective Management (PoEM) is an internationally recognized test for determining the residential status of a company incorporated in foreign jurisdiction. This concept is crucial for all the tax treaties entered into by India as it helps to avoid double taxation.

Corporate Tax – United Arab Emirates

March 26, 2023 2721 Views 1 comment Print

Discover the details of Corporate Tax in the United Arab Emirates (UAE) under Federal Decree-Law No. (47) of 2022. Learn about its impact on businesses, tax rates, and compliance for UAE companies and foreign entities operating in the region. Stay informed about the latest developments in the UAE’s Corporate Tax landscape.

Fees received towards live transmission not taxable as ‘royalty’ in terms of section 9(l)(vi)

March 25, 2023 1068 Views 0 comment Print

ITAT Delhi held that there is no copyright on live events, and therefore, the fee received towards live transmission cannot be taxed as royalty in terms of Section 9(l)(vi).

Income earned from offshore supply not taxable in India as none of operation is carried out in India

March 24, 2023 1863 Views 0 comment Print

ITAT Mumbai held that income earned from offshore supply of escalators and elevators is not taxable in India as assesse didn’t carried out any operations in India.

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