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international taxation

Latest Articles


Tax Avoidance in UK: Key Strategies and Regulations

Income Tax : Explore legal strategies used in tax avoidance in UK, including judicial doctrines, TAARs, GAARs, DOTAS, and the role of HMRC. Lea...

August 13, 2024 324 Views 0 comment Print

UAE Transfer Pricing Compliance Dates

Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....

July 31, 2024 753 Views 0 comment Print

FBAR Submission Guide: U.S. Taxation & Reporting Rules

Income Tax : Understand FBAR requirements for U.S. taxpayers. Learn about reporting foreign financial accounts, penalties for non-compliance, a...

July 21, 2024 534 Views 0 comment Print

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 660 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 840 Views 0 comment Print


Latest News


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 690 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 234 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 70698 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 12336 Views 0 comment Print

UK Suspends Tax Co-Operation With Russia

Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...

March 24, 2022 402 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...

July 15, 2024 582 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

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...

July 8, 2024 309 Views 0 comment Print

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 372 Views 0 comment Print

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 381 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 507 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 2238 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 867 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 609 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 2403 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 4248 Views 0 comment Print


Amounts paid to foreign suppliers for use of computer software through distribution agreement is not Royalty

July 27, 2022 1635 Views 0 comment Print

ITAT held that amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/ suppliers, as consideration for resale/use of computer software through EULAs/distribution agreements are not payment of Royalty.

Challenging CBDT’s MFN Clause Circular No. 3 of 2022 dated 03.02.2022

July 9, 2022 4056 Views 0 comment Print

Delhi High Court accepts Writ Petition challenging CBDT’s MFN Clause Circular No. 3 of 2022. Learn more about this important case.

Canada: Gifts and income tax

July 1, 2022 1122 Views 0 comment Print

Understanding the significance of gifting in Canada: explore the benefits and income tax implications of charitable donations.

USA – Green card by investment (EB 5 Program)

June 25, 2022 1446 Views 0 comment Print

Explore the USA Green Card by Investment (EB 5 Program): a unique path to permanent residency through job creation in rural areas.

ITAT explains impact on taxability when treaty not contains FTS clause

June 22, 2022 5457 Views 0 comment Print

DCIT Vs Michelin ROH Co. Ltd. (ITAT Delhi) Brief facts of the case are that the assessee has a company incorporated in Thailand and offers a number of services, such as, business planning and coordination, engineering services, product research and development etc. to its Indian subsidiary. On offering these engineering services, the assessee obtained a […]

The Beginner’s Guide to Affiliate Marketing Taxes

June 21, 2022 12969 Views 0 comment Print

Affiliate marketing is indeed a profitable business. If you’re new to it, you may wonder if the commissions you’re earning from affiliate links are taxable.

It is not at whim or fancy of a Tax authority to decide as to what constitutes beneficial ownership

June 17, 2022 711 Views 0 comment Print

It is not at the whim or fancy of a tax authority to decide as to what constitutes ‘beneficial ownership’; it is absolutely fundamental that as what constitutes beneficial ownership must also be examined and categorical findings are given as to how these requirements of beneficial ownership are satisfied in the present case.

Mutual Agreement Procedures (MAP)

June 16, 2022 8715 Views 2 comments Print

Learn about Mutual Agreement Procedures (MAP) and how they help resolve double taxation and non-taxation issues in cross-border transactions.

Critical Analysis of Importance of Mutual Agreement Procedure (MAP) In Dispute Resolution

June 13, 2022 3840 Views 0 comment Print

Mutual Agreement Procedure is a dispute resolution mechanism in which taxpayer resorts to solving disputes relating to double taxation-juridical or economic.

Income Tax & FEMA provisions applicable to Non Residents

June 10, 2022 31518 Views 3 comments Print

In this part you can gain knowledge about various provisions of Income-tax Law and Foreign Exchange Management Act, 1999 (FEMA) which are useful to a non-resident. The first part deals with provisions of Income-tax Law and the second part deals with the provisions of FEMA.

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