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Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...
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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 : 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...
Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...
Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...
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Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
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...
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...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
The arm’s length range is an everchanging range as different transfer pricing methods yield a different range of figures which may all be workable. With regard to this, the arm’s length principle can only generate a comparison of the set of conditions that would have been approved between independent enterprises.
Forms 1042, 1042-S, and 1042-T are U.S I.R.S taxation forms dealing with dealings with foreign persons, including non-resident aliens, foreign entities, etc. Forms 1042 and 1042-S need to be filed separately. The main difference between these forms is that form 1042-S is concerned with payments made to foreign nationals, while form 1042 is concerned with […]
Article explains What is Double Taxation Avoidance Agreement (DTAA), and how DTAA helps, types of relief under DTAA, Benefits of DTAA, How to claim DTAA benefits in India and What are the documents required for an NRI to claim DTAA benefit. What if you currently reside in the UK, have invested in India, and are […]
Income from supply of CAS and middleware products to indian customers, does not fall under ‘royalty’ as defined under Section 9(l)(vi) of Income Tax Act, 1961 and Article 12(3) of India- Swiss DTAA.
Navigating Expat Tax in India made easy. Learn about the tax rules, rates, and exemptions for expats working in India.
CIT International Taxation Vs Air India Ltd. (Delhi High Court) Whether ITAT has erred in holding that the rate of deduction of tax in the case of a non-resident who does not have a PAN and whose case does not lie in the exceptions laid down in Sub-Section 7 of Section 206AA of the Act […]
While it may not be perfect, the member countries of the OECD focus have a tendency that the arm’s length principle should govern the judgment of transfer pricing between associated enterprises.
Understand the concept of Foreign Tax Credit (FTC) and its significance in mitigating double taxation on income earned outside India. Explore how Double Taxation Avoidance Agreements (DTAA) play a crucial role in preventing double taxation. Learn about the process of claiming FTC, including filing Form 67 and providing necessary documentation. Gain insights into the relevant details and conditions associated with FTC, ensuring a transparent and justifiable taxation system for Indian residents with foreign income.
Assessee was not having any permanent establishment in India and was providing the service only from Singapore and therefore the provisions of Section 195 of the Act are not applicable.
Property tax in France is based on the rental value of the property and any addition to the property like permanent (not temporary) has to be declared before tax authorities within 90 days, since property tax is based on rental value, so any improvement will increase the rental value of property resulting in increased property tax.
