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international taxation

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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 546 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 690 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 786 Views 0 comment Print

Taxation – The Game of Life – Transfer Pricing & International Taxation

Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...

June 2, 2024 852 Views 0 comment Print

Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...

May 27, 2024 426 Views 0 comment Print


Latest News


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 198 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 67422 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 11595 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 399 Views 0 comment Print

ICRICT Open letter to G20 Heads of State and Government

Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...

October 12, 2021 702 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 435 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 267 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 327 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 345 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 447 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 1989 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 828 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 594 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 2298 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 4191 Views 0 comment Print


AMP expense as International Transaction

May 21, 2022 6540 Views 1 comment Print

Understand the complexities of AMP expense as an international transaction. Learn about the deductions allowed under the Income Tax Act for advertising, marketing, and promotion expenses.

Critical Analysis on Mandatory Binding Arbitration in India

May 18, 2022 2445 Views 0 comment Print

Explore the issue of mandatory binding arbitration in India and its critical analysis. Learn about the impact on double taxation avoidance agreements and dispute resolution mechanisms.

Is Blockchain-based Regulation of Transfer Pricing far-fetched?

May 18, 2022 636 Views 0 comment Print

The paper will firstly discuss cloud-based TP activities and the challenges to regulate them; secondly, analyse the feasibility of regulating cloud-based TP activities through blockchain smart contracts; and finally, scrutinise the risks of regulating cloud-based TP activities through blockchain-based RegTech and provide possible solutions for the same.

Source of international tax law

May 18, 2022 3711 Views 1 comment Print

International trade has existed from the most ancient civilisation of the world like Harappan, Mesopotamia, Egyptian and Roman civilisations. However, the volume of international trade was not so large in those days as it is today.

Advance pricing agreements – a fresh start in India?

May 11, 2022 2247 Views 1 comment Print

In India, the underlying idea behind the scheme of APA is to make tax administration better and efficient by encouraging taxpayers to provide all the data essential for a comprehensive transfer pricing analysis and to motivate them towards engaging a mutual agreement.

Canadian taxation: Role of foreign income

May 9, 2022 1620 Views 0 comment Print

Understanding Canadian taxation and the role of foreign income. Learn about the importance of filing Form T 1135 E to avoid penalties.

Canadian Taxation for the tax year 2021

May 1, 2022 2034 Views 0 comment Print

Learn about Canadian taxation for the tax year 2021. Explore the process of filing income tax returns and understanding form T1.

Master File and CbCR related Forms in India

April 29, 2022 69909 Views 2 comments Print

CBDT) has issued the final rules pertaining to Master File (MF) and Country by Country reporting (CbCR) on 31st October 2017. This is an outcome of the OECD/G20 BEPS Action Plan 13. India has been an active participant of the OECD BEPS (Base Erosion and Profit Shifting) project.

Brief analysis of Indian Resident investing in USA LLC or USA Inc. under Income Tax & FEMA

April 17, 2022 16806 Views 0 comment Print

In this article we shall discuss briefly about taxability and FEMA regulations in relation to Indian resident’s investment in LLC and Inc. in USA INC. INTRODUCTION Inc. is an abbreviation for Incorporated when it is used after a company’s name. Inc. is a corporate body which issue shares of stock to their owners, who are called shareholders. […]

PE or Business Connection – Tax on Income of non-resident in India

April 15, 2022 17664 Views 0 comment Print

Whether incomes of a non-resident are taxable in India, regardless of whether the non-resident assessee has PE or Business Connection in India? There is misconception in the minds of few non-resident assessees that their income are not taxable in India if they have neither business connection nor permanent establishment in India but there are certain […]

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