Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how IRS audits are initiated and conducted to verify tax return accuracy. It highlights taxpayer duties, righ...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
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 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 Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
Income Tax : Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Ar...
Income Tax : ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefi...
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...
Analyze the case of DCIT vs. Software One Pte Ltd. (ITAT Delhi) regarding the taxation of software sales and royalty. Understand the distinction between copyright ownership and distribution rights, as well as the impact of the Supreme Court’s decision in the Engineering Analysis case.
Explore 21 FAQs on Taxation Laws for Foreign Corporates, NRIs, and NRs in India. Understand the intricate regulations governing businesses, investments, and technology exchanges. Learn about Indian government initiatives to create favorable tax policies, stimulate growth opportunities, and reduce uncertainties. Delve into concepts like Place of Effective Management (POEM) and Significant Economic Presence (SEP).
Gain insights into South Africa’s taxation system for the 2023 filing season. Understand individual income tax rates, the process of registration with the South African Revenue Service (SARS), and updates for the upcoming season. Explore the nuances of multiple income sources, unique registration methods, and the impact on economic development. Stay informed about key dates and changes in the taxation landscape.
Classification of royalties and fees for technical services as income in India according to the Income-tax Act, 1961. Explore the definitions and implications of these categories, as well as the concept of Tax Deducted at Source (TDS) and its rates for residents and non-residents.
Learn about the Foreign Account Tax Compliance Act (FATCA) non-tax treaty between India and the United States, its implications on reporting foreign assets, and taxation of investments in India by US tax residents. Understand the complexities of FATCA regulations and the need for expert advice.
Unlock the complexities of tax implications and reporting requirements for U.S. corporations owned by foreign entities, especially Indian shareholders. Dive into withholding taxes, branch profits tax, CFC rules, and reporting obligations, ensuring compliance and optimizing tax outcomes.
Explore G20 Taxation, European Unions efforts against tax avoidance, and the impact of BEPS in 2023. Understand the latest global tax initiatives, including the OECD/G20 Inclusive Framework on BEPS, and how multinational enterprises are subject to a 15% effective minimum tax rate. Stay informed about the Pillar Two GloBE Rules, Safe Harbours, Penalty Relief, GloBE Information Return, and Tax Certainty.
ITAT Mumbai held that foreign tax credit duly available even if form no. 67 is filed along with the revised return as the form is filed before the completion of the assessment.
United States is a highly attractive destination for foreign investors due to its stable economy and business-friendly environment. Many foreign individuals choose to establish Limited Liability Companies (LLCs) in the USA to take advantage of the numerous benefits it offers.
Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement referred to in section 90 and 90A i.e. (for claiming the benefit of DTAA – Double Tax Avoidance Treaties) To, _____________________ _____________________ Declaration : No PE in India Sir, The Following letter is […]
