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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 255 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 246 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 89238 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 471 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 2988 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 4644 Views 0 comment Print


Lease rental from associated enterprises is not royalty – India-USA DTAA

April 15, 2023 1320 Views 0 comment Print

ITAT held that lease rental received by assessee on leasing of alloys cannot be treated as royalty in terms of India-USA DTAA & provisions of section 9(1)(vi)

Is my Income Earned Abroad is Taxable?

April 14, 2023 1167 Views 0 comment Print

NRI taxation under the Indian Income Tax Act, of 1961 applies to those earning income outside the home country. The income tax rules and perks allowed to them are drastically different from those applicable to resident Indians.

G-20 Taxation – United Kingdom (UK)

April 13, 2023 966 Views 0 comment Print

Explore the intricacies of the United Kingdoms tax system, vital for education, jobs, and immigration. Learn about income tax, capital gains tax, private residence relief, marriage allowance, and more. Stay informed about tax rates, bands, and business-related tax in the UK. Source: UK Government Website, Tax Regulations, G-20 Taxation Updates.

Thinking of Investing in US Stocks from India? Brace Yourself with the Taxing Truth

April 12, 2023 8772 Views 1 comment Print

Uncover the taxing truth of investing in US stocks from India. Navigate the complexities of Indian and US tax systems, understand implications on dividends and capital gains, and learn to minimize tax liabilities. CA Mridul Gupta, a practicing Chartered Accountant, breaks down the intricacies to guide investors through informed decision-making. Brace yourself for the taxing reality of investing in the colossal US stock market from the comfort of your home in India.

Non-Filing of Form No. 67 Is Merely A Procedural Error & Foreign Tax Credit Can’t Be Denied

April 12, 2023 6216 Views 0 comment Print

Assessee filed ROI claiming relief u/s 90 but did not file Form No.67. Form was subsequently filed beyond the due date as per under Rule. CPC did not give credit for foreign tax.

Tax rate on Non-resident in India for FTS & Royalty services doubled from 01.04.2023

April 11, 2023 46158 Views 5 comments Print

As of April 1, 2023, India has doubled tax rates for non-residents on Fees for Technical Services (FTS) and Royalty to 20%. Explore the impact, mandatory filings, and potential defenses against these changes.

UAE Small Business Relief- A Deep Dive

April 10, 2023 2526 Views 0 comment Print

Small Business Relief is intended to support start-ups and other small or micro businesses by reducing their Corporate Tax burden and compliance costs. The Ministerial Decision on Small Business Relief specifies the revenue threshold and conditions for a taxable person to elect for Small Business Relief and clarifies the provisions of the carried forward Tax Losses and disallowed Net Interest Expenditure under the Small Business Relief scheme.

G-20 Taxation – Japan

April 8, 2023 1431 Views 0 comment Print

Due to initiation of Japanese taxation in my earlier articles, let me narrate the steps taken by Jetro, Japan external trade organization (web page with official tax information), and National Tax Agency to update our knowledge for the tax year 2022, particularly in view of G 20 Taxation compilation merging with Indian presidentship of the same.

Drop shipping businesses in USA & Indian Tax Residents Tax implications

April 4, 2023 4683 Views 0 comment Print

Discover the tax implications for dropshipping businesses in the USA and India. Learn about entity types, income tax, international tax forms, Indian laws, and tax treaties to navigate the complexities and ensure compliance while maximizing profits.

Mere usage of name of Foreign AE not convert a transaction into international transaction

April 3, 2023 1086 Views 0 comment Print

Philips India Ltd. vs ACIT (ITAT Kolkata) In many cases, licensed manufacturers operate as risk-bearing entrepreneurs, and there is no existence of an ‘agreement’ or ‘arrangement’ or ‘understanding’ with the AE regarding AMP expenditure, the initial onus is on the revenue to show that there is an international transaction for AMP spend. The mere fact […]

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