Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
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 held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
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 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...
Explore Supreme Court’s landmark decision on Most Favored Nation (MFN) clause in India’s Double Taxation Avoidance Agreements (DTAA) and its implications on international taxation.
Explore Vienna Convention’s role in international taxation, focusing on principles like good faith, territorial scope, and treaty interpretation. Learn key insights for navigating Double Taxation Avoidance Agreements (DTAAs).
Explore the Bengal Tiger Line vs. DCIT case: ITAT Chennai rules in favor of the assessee, allowing benefits under India-Singapore DTAA for Vessel Handling Charges.
Delhi HC ruled on appeal in PCIT vs Global Logic India Ltd, upholding exclusion of comparables due to absence of segmental info & treatment of foreign exchange gain/loss as operating income/operating loss
Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital
Delhi High Court upholds ITAT’s decision: Advertising, Marketing, and Promotion (AMP) expenses by Wrigley India Pvt. Ltd. not considered an international transaction.
Delhi High Court rules on income tax and administrative services provided by a Singapore entity to its Indian affiliate. Analysis of the case Commissioner of Income Tax vs. Bio-Rad Laboratories.
Explore the intricacies of Permanent Establishment in international taxation, from UN Model to domestic laws. Learn about key provisions, tests, and recent developments. Contact us for clarity on International Taxation/DTAA.
Explore the implications of the Indian Supreme Court’s recent judgment on Double Taxation Avoidance Agreements (DTAA) and Most Favored Nation (MFN) clauses, affecting European MNCs.
ITAT Delhi rules in favor of a Canadian resident, allowing them to benefit from the India-Canada Double Taxation Avoidance Agreement (DTAA). Learn more in this article.
