Income Tax : Explore legal strategies used in tax avoidance in UK, including judicial doctrines, TAARs, GAARs, DOTAS, and the role of HMRC. Lea...
Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....
Income Tax : Understand FBAR requirements for U.S. taxpayers. Learn about reporting foreign financial accounts, penalties for non-compliance, a...
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 : 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 : 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 : 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...
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 […]
India has gained an ill-reputation regarding its retrospective taxation laws in the past decade, especially due to the amendments made to Section 9 by the Finance Act, 2012. Retrospective operation of this amendment gave rise to three notable international tax disputes, namely the Vodafone International Holdings BV case, the Cairn Energy PLC case, and the […]
The Double Taxation Avoidance Agreement (DTAA), inter alia, provide rules and mechanisms for allocation of taxing rights amongst the treaty partners; avoidance of economic and juridical double taxation; and resolution of taxation not in accordance with the treaty through the Mutual Agreement Procedure (‘MAP’). MAP is an inbuilt and alternate tax dispute resolution mechanism available to the taxpayers under the DTAAs. It is […]
Recently, the Mumbai bench of ITAT has given its final order in the case of Morgan Stanley Mauritius Co. Ltd. v. DCIT,[1] holding that dividend payments made by a foreign company to its domestic depository which were subsequently transferred to IDR holders are not taxable in India under the Indo-Mauritius DTAA. Despite the dividend income […]
A company is typically financed (or capitalized) through a mixture of debt and equity. Thin capitalization refers to the situation in which a company is financed through a relatively high level of debt compared to equity. Thinly capitalized companies are sometimes referred to as ‘highly leveraged’ or ’highly geared’. As a result of having a […]
The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Saint Vincent and The Grenadines for the Exchange of Information and Assistance in Collection with respect to Taxes.
You were fed with newspapers headlines informing G7 gave its consent for Biden’s global tax proposal which ensures right companies pay right tax in right countries. Mr. Joseph Robinette Biden Jr, the current American president brought the tax reform known as ‘Made in America tax proposal’ which is reproduced below for our detailed discussion. https://home.treasury.gov/system/files/136/MadeInAmericaTaxPlan_Report.pdf […]
