Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
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 held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
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 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...
In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.
Learn about the tax dispute between Diamond Manufacturing Management and the Indian Revenue Authority, involving fees for technical collaboration and the absence of Permanent Establishment.
Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation Avoidance Agreements (DTAA) in India.
Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover strategies to address this pressing issue.
Learn about tax implications of offshore indirect transfers of Indian capital assets by non-resident entities. Explore Vodafone case, amendments to Income Tax Act, and Explanation 5 of Section 9(1)(i).
Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal compliance, and tax considerations for successful transactions.
Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs, and penalties for non-compliance.
Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.
CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the order of ITAT that ESPN Distribution does not constitute a PE in India and income earned from sports channel distribution cannot be taxed as royalty under provisions of the ITA read with India-Mauritius DTAA. Background […]
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.
