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international taxation

Latest Articles


Switzerland Suspends Unilateral MFN Clause Application in Tax Treaty with India

Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...

March 4, 2025 255 Views 0 comment Print

USA Taxation, 2024: Updated guidelines for Corporates

Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...

February 24, 2025 990 Views 0 comment Print

Delhi High Court Rules on Technical Services in International Logistics

Income Tax : CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a si...

February 21, 2025 246 Views 0 comment Print

USA Taxation 2024: Updated Guidelines for Individuals

Income Tax : Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn abo...

February 13, 2025 843 Views 1 comment Print

Income Tax Return Filing Guide for Proprietors in the USA

Income Tax : Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and pena...

February 9, 2025 1038 Views 0 comment Print


Latest News


CRS & FATCA: Tax Transparency & Disclosure of Foreign Assets & Income

Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...

January 3, 2025 888 Views 0 comment Print

Budget 2024: New Rules for Including Foreign Taxes in Total Income

Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...

July 24, 2024 846 Views 0 comment Print

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 366 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 89238 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 13236 Views 0 comment Print


Latest Judiciary


Mere operational links or subsidiary relationships do not confer PE status: Delhi HC

Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...

February 24, 2025 471 Views 0 comment Print

CPC Erred in denying Loss Carry-Forward to Company Eligible for Extended Due Date U/s. 92E: ITAT Ahmedabad

Income Tax : CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of In...

February 22, 2025 333 Views 0 comment Print

IT support payments not taxable as FTS due to failure of ‘make available’ test under India-UK DTAA: ITAT Delhi

Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...

February 9, 2025 276 Views 0 comment Print

Carried forward losses cannot be set-off against exempt capital gains under DTAA

Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...

February 8, 2025 450 Views 0 comment Print

Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC

Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...

January 29, 2025 633 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 3309 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 984 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 660 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 2988 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 4644 Views 0 comment Print


Analysis of Section 9A of Income Tax Act, 1961: Certain Activities Not to Constitute Business Connection in India

August 4, 2023 8478 Views 0 comment Print

Explore a comprehensive analysis of Section 9A of the Indian Income Tax Act, 1961. Learn how it impacts offshore funds’ business connections in India.

Global Minimum Corporate Tax (GMCT)

August 4, 2023 3372 Views 0 comment Print

Exploring the role, challenges, and impact of the OECD’s proposed Global Minimum Corporate Tax (GMCT) on India and global business.

25 FAQs on Significant Economic Presence for Non Residents Operating in India

July 27, 2023 20475 Views 0 comment Print

Explore 25 FAQs on Significant Economic Presence (SEP) for Non-Residents in India. Understand the impact of SEP on digital and e-commerce business models, reasons for its application, income tax implications, criteria, challenges, and immunity through Double Taxation Avoidance Agreements (DTAA). Stay informed about legal obligations, special roles for professionals, and the governments challenges in managing income tax leakages in the digital and e-commerce sectors. Expert insights for NRs operating in India.

Taxation of Expats in India: Residence-Based System & DTAA Explained

July 24, 2023 2349 Views 0 comment Print

Get insights into the tax obligations of expats in India, the residence-based taxation system, and Double Taxation Avoidance Agreements (DTAA). Understand tax deductions, compliance, and the GST impact on expats’ income.

ITAT Allows Foreign Tax Credit for Taxable Employment Bonus

July 22, 2023 615 Views 0 comment Print

Explore the critical decision in Souvik Mukherjee Vs ITO (ITAT Delhi) regarding taxation of a bonus received abroad, and how it impacts Foreign Tax Credit regulations.

Applicability of POEM on Foreign Company in India

July 20, 2023 15678 Views 0 comment Print

Get answers to 41 frequently asked questions about the POEM (Place of Effective Management) concept for companies located outside India but controlled from India. Understand the implications, criteria, and international perspectives on POEM.

Mere passport insufficient to confirm assessee’s US tax residency

July 14, 2023 792 Views 0 comment Print

An in-depth analysis of the case Parag Bhikhubhai Patel vs ITO, exploring implications of using passports to confirm US tax residency for NRIs under India-USA Tax Treaty

India’s Drive for Tax Transparency and Balanced Treaty Negotiations

July 13, 2023 897 Views 0 comment Print

Discover how India is adhering to global tax standards and enhancing its treaty network. Explore the steps taken, challenges faced, and opportunities available in India’s drive for tax transparency and fair treaty negotiations.

Understanding Form 15CA and Form 15CB: A Comprehensive Guide

July 4, 2023 8325 Views 0 comment Print

In this article, we provide a detailed analysis of Form 15CA and Form 15CB, their purpose, when they are required, and how to file them. Discover the mandatory information needed for filing and the transactions exempt from Form 15CA. Read on to ensure compliance with tax regulations for remittances to non-residents.

AO cannot reject TRC without providing relevant information to petitioner

June 30, 2023 750 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.

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