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 : Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn abo...
Income Tax : Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and pena...
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 : 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 : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...
Income Tax : CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of In...
Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...
Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...
Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...
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...
With the increasing rings of cellular phones, any CPA from USA will tell you the sleepless nights he/she encounters these days due to the current US tax season 2021-22. A large scrutiny of past returns as early as 2001-2003 in my client’s case, withholding of passport for non-filing of tax returns, and regular audit of […]
An expatriate means a person visiting India or an Indian visiting outside India for employment purposes. In this article, we shall discuss the taxation & legal formalities to be followed by Expats on arrival in India. LEGAL FORMALITIES TO BE FOLLOWED BY EXPATS 1. Registration of Foreign National with Foreigners Regional Registration Officer (FRRO) All […]
Generally speaking, Branch Profit Tax is a tax imposed on effectively connected earnings / income of a branch (or entity) in a contracting state (country, in common parlance) of a foreign entity when those earnings are repatriated, or deemed repatriated, to the home country of such foreign entity. Currently, there is no concept of additional […]
Well Friends, this seemingly short and pinpointed question (Can GAAR Override DTAA?), has in-seemingly long and abstract answer, in the absence of any specific legal precedent in this regard, in India, as of now. However, in this article, I am making an honest and sincere attempt to find a plausible, logical and well-reasoned answer to […]
In 2014, the IRS issued Notice 2014-21, 2014-16 I.R.B. 938 explaining that virtual currency is treated as property for Federal income tax purposes and providing examples of how longstanding tax principles applicable to transactions involving property apply to virtual currency. With our income tax authorities going to bite virtual currency as explained in the recent budget […]
Section 6(1) of IT Act, 1961 offers two sets of parameters to determine whether a particular person is an Indian citizen or not. If the said individual falls under any one of the following criterias, he/she will be a resident of the country.
Protocol to India’s Double Taxation Avoidance Agreements (DTAAs) with a portion of the nations, particularly European States and OECD individuals (The Netherlands, France, the Swiss Confederation, Sweden, Spain and Hungary) contains an arrangement, alluded to as the Most-Favored-Nation (MFN) provision.
The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (particularly to dividend withholding rates) available in the Protocol to some of the DTAAs with OECD member States. India’s DTAAs with countries, namely Slovenia, Colombia and Lithuania, provide for lower rate of source taxation with respect to certain items of income. However, these States were not members of the OECD at the time of the conclusion of their DTAAs with India and have become members of the OECD thereafter.
Germany one of the backbones of European economy has merged with the world’s latest attempt of 137 nations to check the leak of national taxation to tax havens by adopting in its cabinet meet on 31 March 2021 to have its draft Defence against Tax Havens Act (Steueroasen-Abwehrgesetz). It clearly sends the message of acting […]
In The United State of America, Tax is imposed on both federal and state level. Federal and state taxes are completely separate and each has its own authority to charge taxes. The federal government does not have the right to interfere with state taxation. Each state has its own tax system that is separate from the […]
