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...
Learn the essentials of Form 10F filing for non-residents seeking DTAA benefits in India, including required documents, filing process, and online submission.
Detailed analysis of Finastra International Financial Systems PTE Ltd. Vs ACIT(International Taxation) case where ITAT Delhi ruled that software sales to Indian entities are not taxable under Article 12(3) of India-Singapore DTAA.
In a landmark decision, ITAT Mumbai rules in favor of Abu Dhabi Investment Authority, stating that a fraud mobile number cannot deny tax treaty benefits. Full text of the order included.
Delve into the detailed analysis of DCIT Vs AD2PRO Media Solutions Pvt. Ltd. case where marketing services rendered by a US entity in India were deemed not taxable, offering insights into tax benefits.
ITAT Bangalore rules receipts from the sale of online videos by Plural Sight LLC to Indian clients are not taxable as ‘Royalty’ under India-USA DTAA.
Discover how the OECD’s introduction of Pillar One Amount B in 2024 streamlines transfer pricing for marketing and distribution, enhancing fairness and compliance for multinational enterprises.
Explore the complexities of computing trading income and deductible expenses for UK income tax, including the role of GAAP, statutory provisions, and tax law adjustments.
Delhi High Court judgment in CIT vs. RELX Inc clarifies legal database subscriptions aren’t copyright transfers or royalty. Insights on taxation implications.
Delhi ITAT rules in favor of Volvo Information Technology AB, declaring receipts from Indian entities not taxable as royalty, aligning with SC precedents.
Learn about tackling tax avoidance in the UK with the Ramsay doctrine and GAAR. Explore their implications and effectiveness in combating tax avoidance strategies.
