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...
Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm’s length pricing, methods for computation, and the impact of secondary adjustments.
Explore the ITAT Delhi ruling on the eligibility of management service fees paid to non-resident AEs under section 37(1) of the Income Tax Act in the case of Iris Worldwide Integrated Marketing Pvt. Ltd vs. DCIT.
Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest at arm’s length rate.
HCG Global Communications Ltd. vs. DCIT (ITAT Bangalore) case ruling: Telecom interconnect usage payments received by a foreign company from an Indian operator deemed non-taxable as ‘royalty’ under the Income Tax Act.
Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and changes in taxation laws.
Understanding small business tax obligations is a fundamental part of running a successful enterprise. At its core, these obligations revolve around accurately reporting income and expenses to the appropriate tax authorities, which in turn determines the amount of tax owed by the business. Small businesses must navigate through various types of taxes including income tax, […]
Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxation of incomes, and DTAA benefits.
Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their effectiveness, compliance, and applicability in resolving transfer pricing disputes.
Learn about the UK’s plan to abolish the non-domiciled tax rule after 225 years, its implications for Indians, and the new residence-based taxation policy effective from April 2025.
Explore the comprehensive requirements of Action 13 of the BEPS Action Plan on transfer pricing documentation, including local file, master file, and country-by-country reporting. Learn about implementation thresholds and India’s incorporation of these standards.