Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
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 : 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 : 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 : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...
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...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
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 : 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...
In present facts of the case, the Hon’ble Tribunal relied upon the previous Judgments passed in the assesse own case and have observed that agents of the assessee did not have the necessary authority to conclude the contracts of the assessee and, on that premise, it was held that there is no agency PE of assessee in India and therefore Assessee was not taxable in India.
ITAT held that in case A comparable having an extraordinary financial event of Merger and Acquisition (M& A) during the year the same cannot be considered as functionally comparable for transfer pricing (TP) comparability analysis.
Target marketing on overseas social media or automated advertising platforms not taxable as ‘Royalty’ In a major relief to taxpayers availing online marketing services from social media platforms like Facebook, the Bangalore bench of Income Tax Appellate Tribunal (ITAT) recently ruled in the case of Urban Ladder Home Décor Solutions Pvt. Ltd. Vs ACIT that […]
We often come across with cases where there has been double taxation on the same income both from source and resident countries. Typically from an India tax perspective, in case of ‘resident and ordinarily resident’ (ROR) having investments abroad, this scenario is quite common. In order to mitigate such double taxation implications, Section 90 of […]
As the world moves increasingly towards economic integration and globalization there is a lot of cross border trade, investment and business which will only increase as more and more developing and least developed countries open up their borders for more business with the international community.
Bombay Chartered Accountant’s Society has made a representation to CBDT Chairman and draw his attention towards the difficulties faced, in recent times, by resident taxpayers, in claiming Foreign Tax Credit (FTC) for their income abroad, while filing their return of Income in India. Full Text of their representation is as follows:- Bombay Chartered Accountant’s Society […]
Technology plays a vital role in today’s world making our daily lives simpler. From medical diagnoses to business operations, from communication to education, everything seems impossible without technology. This pandemic has evidenced the same. Life would have come to stand still without it. But nothing stopped. Technology has infiltrated every aspect of our lives, changing […]
Non-residents are subject to tax in India with respect to the income accrued/ deemed to accrue in India or received/ deemed to be received in India as per the provisions of the Income Tax Act, 1961 (‘Act’). While the international tax landscape is seeing a lot of changes in form of OECD BEPS Pillar 1 […]
21st century world largely operates under a Global Economic System. International Business is the buzz all around & businesses are not confined to boundaries. It involves cross border transactions both in goods and services. Conducive International Business Environment is imperative for multinational companies to operate and perform. In order to promote cross border trade, the […]
Inflow Technologies Private Limited Vs ACIT (ITAT Bangalore) The assessee, as a part of share purchase agreement, during the business structuring had given a corporate guarantee to one of its group supplier CISCO for supplies made to its AE (Inflow Singapore). According to the assessee, it did not intend to get any remuneration for the […]
