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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 252 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 243 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 89229 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 468 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 2985 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 4638 Views 0 comment Print


ITAT Ruling: Taxation of Software Sales and Royalty Payments

June 29, 2023 927 Views 0 comment Print

Analyze the case of DCIT vs. Software One Pte Ltd. (ITAT Delhi) regarding the taxation of software sales and royalty. Understand the distinction between copyright ownership and distribution rights, as well as the impact of the Supreme Court’s decision in the Engineering Analysis case.

21 FAQs on Taxation Laws for Foreign Corporate + NRIs + NRs in India

June 22, 2023 3792 Views 1 comment Print

Explore 21 FAQs on Taxation Laws for Foreign Corporates, NRIs, and NRs in India. Understand the intricate regulations governing businesses, investments, and technology exchanges. Learn about Indian government initiatives to create favorable tax policies, stimulate growth opportunities, and reduce uncertainties. Delve into concepts like Place of Effective Management (POEM) and Significant Economic Presence (SEP).

South Africa’s 2023 Tax Filing Season Insights

June 21, 2023 828 Views 0 comment Print

Gain insights into South Africa’s taxation system for the 2023 filing season. Understand individual income tax rates, the process of registration with the South African Revenue Service (SARS), and updates for the upcoming season. Explore the nuances of multiple income sources, unique registration methods, and the impact on economic development. Stay informed about key dates and changes in the taxation landscape.

Unraveling the Mysteries of Royalties and Fees for Technical Services in India

June 13, 2023 23322 Views 0 comment Print

Classification of royalties and fees for technical services as income in India according to the Income-tax Act, 1961. Explore the definitions and implications of these categories, as well as the concept of Tax Deducted at Source (TDS) and its rates for residents and non-residents.

16 FAQ’s on FATCA Non-Tax Treaty (Agreement) between India and USA

June 8, 2023 4443 Views 0 comment Print

Learn about the Foreign Account Tax Compliance Act (FATCA) non-tax treaty between India and the United States, its implications on reporting foreign assets, and taxation of investments in India by US tax residents. Understand the complexities of FATCA regulations and the need for expert advice.

U.S. Corporations Owned by Foreign/ Indian Shareholders – Comprehensive Tax Implications and Reporting Requirements

June 6, 2023 852 Views 0 comment Print

Unlock the complexities of tax implications and reporting requirements for U.S. corporations owned by foreign entities, especially Indian shareholders. Dive into withholding taxes, branch profits tax, CFC rules, and reporting obligations, ensuring compliance and optimizing tax outcomes.

G 20 Taxation – European Union – BEPS, 2023

May 18, 2023 1080 Views 0 comment Print

Explore G20 Taxation, European Unions efforts against tax avoidance, and the impact of BEPS in 2023. Understand the latest global tax initiatives, including the OECD/G20 Inclusive Framework on BEPS, and how multinational enterprises are subject to a 15% effective minimum tax rate. Stay informed about the Pillar Two GloBE Rules, Safe Harbours, Penalty Relief, GloBE Information Return, and Tax Certainty.

Foreign tax credit against form 67 filed before completion of assessment is duly allowable

May 10, 2023 2940 Views 0 comment Print

ITAT Mumbai held that foreign tax credit duly available even if form no. 67 is filed along with the revised return as the form is filed before the completion of the assessment.

Understanding Tax Implications for Foreign (Indian) Individuals Owning a single member LLC in the USA

May 9, 2023 4239 Views 0 comment Print

United States is a highly attractive destination for foreign investors due to its stable economy and business-friendly environment. Many foreign individuals choose to establish Limited Liability Companies (LLCs) in the USA to take advantage of the numerous benefits it offers.

Format of Declaration of no PE in India and Form No. 10F

May 8, 2023 89229 Views 0 comment Print

Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement referred to in section 90 and 90A i.e. (for claiming the benefit of DTAA – Double Tax Avoidance Treaties) To, _____________________ _____________________ Declaration : No PE in India Sir, The Following letter is […]

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