Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...
Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
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 : 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...
Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...
Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...
Income Tax : On 3rd October, 2021, the International Consortium of International Journalists (ICIJ) has come out with what is claimed to be a 2...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...
Income Tax : In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren't taxable in India...
Income Tax : In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren't considered FTS under ...
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...
Let me wish you ‘Akemashite omedetou gozaimasu. (formal): あけましておめでとうございます’ a Happy New Year in Japanese. Let us proceed with our learning of the latest developments in Japanese taxation. Due to initiation of Japanese taxation in our earlier articles in an exhaustive manner, let me narrate the steps taken by Jetro, Japan external trade organization (web […]
Independent work is quite difficult, and it involves a lot of liability. You should care for your workers, handle your cash, settle your assessments, and present your government forms. Whether or not independently employed, people are needed to pay personal assessment paying little heed to their type of revenue. Nonetheless, independently operated workers often neglect […]
QUESTION: The Income Tax Act, 1961 provides for taxation of a certain income earned in India by Mr. X a non-resident. The DTAA ,which applied to Mr. X provides for taxation of such income in the country of his residence. Examine ,is Mr. X is liable to pay tax on such income earned by him […]
In continuation of my writing on the taxation of the top 25 GDP rated countries, South Korea with its unique income tax for individuals deserves special treatment. I got the latest information from the web site of National Tax Service, (NTS) the government owned one to help with tax information. Proper reference is given at […]
In our tribute to top 25 GDP nations of the world, South Korea has shown a remarkable story to be written in golden letters. Like any Asian country, this lateral part of the century 2000 along with the next one naturally belongs to this quality obsessed nation. Luckily, I came across its taxation in a […]
I am on a series of articles to explain basically the income tax of top 25 GDP countries which invite most of the Indian exporters/experts from India who help these countries to grow, prosper, and distribute wealth among those associated with them. It is time for United Kingdom economy to get the priority. Income tax […]
ITO Vs Rajeev Suresh Ghai (ITAT Mumbai) It is always useful to bear in mind the fact that, on the first principles, the trigger for taxation of an income in a source jurisdiction is either the economic activity or the linkage of an income with that jurisdiction, and that in the absence of such a […]
Government of one country enters into an agreement with the Government of another country or a specified territory for (i) Granting of relief in respect to double taxation (ii) Avoidance of double taxation (iii) Exchange of information (iv) Recovery of income tax. Such agreement is called a Double Taxation Avoidance Agreement (DTAA). Often with the […]
Qualcom Technologies Inc. Vs DCIT (ITAT Delhi) ITAT held that Considering the assessment order of the AO wherein he has followed the findings given in earlier assessment years and considering the fact that the same agreement is being carried on since A.Y.2005-06, we do not find any reason in differing with the view taken by […]
Transfer pricing provisions was incorporated in the Income Tax Act in April 2001 and now it has travel the journey of almost two decades in India. If we give one line principal to the transfer pricing provisions then it is benchmarking of international transactions entered with associated enterprises with comparables transactions (internal or external comparables) […]
