Follow Us:

international taxation

Latest Articles


Benefit to Non-Residents under Income Tax Act, 1961

Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...

July 3, 2026 114648 Views 0 comment Print

​International Business- Income Tax Sections to be remembered

Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...

June 30, 2026 18923 Views 1 comment Print

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 455015 Views 28 comments Print

Why Your Indian Subsidiary Abroad Might Be Triggering Tax Residency You Never Signed Up For?

Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...

June 25, 2026 432 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 2793 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 2094 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 1587 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 906 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 121902 Views 0 comment Print


Latest Judiciary


ITAT Deletes AMP TP Adjustment as No International Transaction Existed

Income Tax : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...

June 28, 2026 129 Views 0 comment Print

Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC

Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...

June 20, 2026 114 Views 0 comment Print

ITAT Partly Allows TP Appeal, Revises Comparable Selection for ALP Determination

Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...

June 17, 2026 246 Views 0 comment Print

No DAPE Where Distributors Act on Principal-to-Principal Basis ITAT Delhi

Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...

March 12, 2026 438 Views 0 comment Print

Interconnect Service Charges Not Royalty: Karnataka HC Dismisses Appeal

Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....

December 10, 2025 549 Views 0 comment Print


Latest Notifications


India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1269 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1797 Views 0 comment Print

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 4563 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 1464 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 933 Views 0 comment Print


Thin Cap Adjustment Provisions Under Section 94B

January 20, 2024 14667 Views 2 comments Print

Explore the Thin Cap Adjustment Provisions under Section 94B of the Income Tax Act, addressing base erosion and profit shifting. Learn about its impact on NBFCs, start-ups, and global approaches.

Significant Economic Presence (SEP): Implications for Non-Residents in India

January 20, 2024 4653 Views 0 comment Print

This article sheds light on the concept of Significant Economic Presence (SEP) under Section 9 of the Indian Income Tax Act, 1961, and its implications for non-residents.

Delhi HC Upholds ITAT Order Excluding Comparables Due to Functional Dissimilarity

January 19, 2024 882 Views 0 comment Print

Delhi High Court upholds ITAT’s decision to exclude comparables Accentia, Eclerx, Mold-Tek, and TSR in the PCIT vs. Honeywell International transfer pricing case.

Avoidance of Double Taxation agreement

January 17, 2024 3264 Views 0 comment Print

Explore the impact of Double Taxation on international business, the role of Double Taxation Avoidance Agreements (DTAA), benefits, and case laws. Learn how to apply DTAA for tax relief

Software Sale Payment Not Royalty under Indo-Singapore DTAA: Delhi HC

January 17, 2024 1197 Views 0 comment Print

Delhi High Court upholds ITAT order: Payments received for software sale/supply not considered royalty under India-Singapore Double Taxation Avoidance Agreement (DTAA).

Section 248 Inapplicable to Tax Liability in Dividend Distribution by a Company

January 16, 2024 1344 Views 0 comment Print

Explore the Madras High Court’s ruling on Section 248’s inapplicability to dividend declarations. Detailed analysis and implications of the judgment.

Delhi High Court Closes CCD Taxation Appeals, Awaits Supreme Court’s Final Decision

January 16, 2024 1755 Views 0 comment Print

Delhi High Court disposes of CIT Vs Zaheer Mauritius appeals, addressing taxability and capital gains nature of Compulsorily Convertible Debentures under India-Mauritius DTAA.

BEPS Principles and MLI Framework in India’s PE Status under DTAA

January 15, 2024 2769 Views 0 comment Print

Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.

Exploring The Emerging Areas of International Taxation

January 5, 2024 1536 Views 0 comment Print

Explore the dynamic landscape of international taxation, delving into emerging areas like digital companies, cross-border transactions with cryptocurrencies, and the evolving tax landscape for multinational corporations. Stay informed on transfer pricing regulations and ensure compliance for a seamless global business experience.

Form 10F Guide: Tax Treaty Benefits for Non-Resident Receiving Indian Income

January 5, 2024 33483 Views 3 comments Print

Understand Form 10F for non-residents receiving income from India. Learn about electronic filing, recent changes, and the benefits of claiming tax treaty relief with Tax Residency Certificate (TRC).

Search Post by Date
July 2026
M T W T F S S
 12345
6789101112
13141516171819
20212223242526
2728293031