Income Tax : Explore how MNCs used the Double Irish & Dutch Sandwich strategy to avoid taxes and the global efforts made to close these loophol...
Income Tax : Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within ...
Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...
Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...
Income Tax : CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a si...
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 : It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing t...
Income Tax : ITAT Delhi rules Crocs Inc.'s service income not taxable in India under DTAA, as services did not "make available" technical knowl...
Income Tax : ITAT Mumbai rules Sita USA's airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2...
Income Tax : ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore ...
Income Tax : ITAT Mumbai allows tax exemption on capital gains for NRI under India-Singapore DTAA, rejecting AO's classification of mutual fund...
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...
Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm’s length pricing in international and domestic transactions.
New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance burdens for taxpayers.
The Finance Bill 2025 amends Section 9 to clarify that export-related purchases by non-residents won’t be considered as significant economic presence in India.
Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings in transfer pricing for taxpayers.
Delhi HC rules Samsung India not a ‘Permanent Establishment’ of Samsung Korea. No tax liability under India-Korea DTAA for seconded employees’ roles.
Learn how Indian taxpayers can claim Foreign Tax Credit to avoid double taxation on overseas income. Steps, eligibility, and documentation requirements explained.
Summary: Effective July 23, 2024, buyers of immovable property from Non-Resident Indians (NRIs) must deduct TDS at a revised rate of 12.5%, inclusive of a 15% surcharge and 4% health and education cess, totaling an effective TDS rate of 14.95%. Compliance with Section 195 of the Income Tax Act requires the buyer to deduct TDS […]
Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricing adjustments to international dealings.
Summary: An Income Tax Clearance Certificate (ITCC) is required under Section 230 of the Income Tax Act, 1961, for non-residents earning income in India before leaving the country. This certificate ensures that the individual has cleared all tax dues on their income earned during their stay. Non-residents visiting India for employment, business, or professional purposes […]
Understand foreign income tax compliance, classification, and whether refiling is necessary. Learn key steps to avoid penalties and respond to tax notices accurately.
