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international taxation

Latest Articles


Global Tax Avoidance: Double Irish, Dutch Sandwich

Income Tax : Explore how MNCs used the Double Irish & Dutch Sandwich strategy to avoid taxes and the global efforts made to close these loophol...

April 15, 2025 510 Views 0 comment Print

Analysis of Impact & Effectiveness of Bilateral Investment Treaties

Income Tax : Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within ...

March 20, 2025 426 Views 0 comment Print

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 321 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 1119 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 324 Views 0 comment Print


Latest News


CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 1344 Views 0 comment Print

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 987 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 858 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 411 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 93369 Views 0 comment Print


Latest Judiciary


Exempt LTCG Under India-Mauritius DTAA Not Adjustable Against Taxable Losses: ITAT Mumbai

Income Tax : It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing t...

April 22, 2025 54 Views 0 comment Print

Planning, HR, Legal & IT Support Not Taxable as FTS Under India-USA DTAA, Citing ‘Make Available’ Test

Income Tax : ITAT Delhi rules Crocs Inc.'s service income not taxable in India under DTAA, as services did not "make available" technical knowl...

April 20, 2025 387 Views 0 comment Print

Receipts from Passenger System Solutions not taxable as FTS in India: ITAT Mumbai

Income Tax : ITAT Mumbai rules Sita USA's airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2...

April 15, 2025 192 Views 0 comment Print

Capital Gains on Mutual Funds by Singapore Resident Not Taxable in India: ITAT Mumbai

Income Tax : ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore ...

April 15, 2025 1473 Views 0 comment Print

Capital Gains on Mutual Fund Units Not Taxable in India for Singapore Resident Under DTAA: ITAT Mumbai

Income Tax : ITAT Mumbai allows tax exemption on capital gains for NRI under India-Singapore DTAA, rejecting AO's classification of mutual fund...

April 4, 2025 1314 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 3411 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 1017 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 708 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 3084 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 4761 Views 0 comment Print


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

February 24, 2025 636 Views 0 comment Print

Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software revenue, interest income & vendor financing.

USA Taxation, 2024: Updated guidelines for Corporates

February 24, 2025 1119 Views 0 comment Print

Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay compliant with updated IRS guidelines.

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

February 22, 2025 348 Views 0 comment Print

CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of Income Tax Act due to international transactions: ITAT Ahmedabad

Delhi High Court Rules on Technical Services in International Logistics

February 21, 2025 324 Views 0 comment Print

CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a significant ruling delivered on February 13, 2025, the Delhi High Court dismissed a series of appeals by the Commissioner of Income Tax (International Tax) against Expeditors International of Washington Inc., clarifying the scope of “Fees for […]

USA Taxation 2024: Updated Guidelines for Individuals

February 13, 2025 966 Views 1 comment Print

Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn about filing status and capital gains.

Income Tax Return Filing Guide for Proprietors in the USA

February 9, 2025 1110 Views 0 comment Print

Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and penalties for non-compliance.

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

February 9, 2025 306 Views 0 comment Print

ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ test under India-UK DTAA.

Taxation of International Transactions In India Under Income Tax Act 1961

February 9, 2025 2238 Views 0 comment Print

Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, and compliance essentials.

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

February 8, 2025 594 Views 0 comment Print

ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxability, and judicial precedents.

Tax Implications for NRIs Selling Property in India

February 7, 2025 6729 Views 3 comments Print

Learn about the tax implications for NRIs selling property in India, including capital gains, TDS, exemptions, and repatriation of proceeds.

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