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...
1. There have been a lot of ambiguities have arisen regarding the payment made to a non-resident entity for the grant of the use of computer software by a businessman in India for internal business purposes. 2. The Income Tax Department has been treating such payments as royalty and accordingly, bringing the same to tax in India.
Engineering Analysis Centre of Excellence Private Limited Vs CIT (Supreme Court of India); Civil Appeal Nos. 8733-8734 of 2018; Dated: 02/03/2021 Issues Involved : 1. The amounts paid by the residents in India to non-resident, foreign software suppliers; amounts to royalty, there by necessitating withholding of taxes under section 195 of Income Tax Act. 2. […]
There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]
Once the existence of dependent agency permanent establishment was wholly tax-neutral, unless it was shown that the agent had not been paid an arm’s length remuneration, and when it was not the case of AO that the agents had not been paid an arm’s length remuneration, the question regarding the existence of dependent agency permanent establishment, i.e., under article 5(4), was a wholly academic question.
The complexities of UAE VAT regime and the Federal Tax Authority or FTA’s current targeting for tax evasion and avoidance means tax disputes are increasingly arising. There will be instances wherein you disagree with an assessment or decision that is made by the local tax authority. If you are in complete disagreement with a certain […]
HIGHLIGHTS OF THE UNION BUDGET-2021 -22- Tax proposals- International Taxation – 1. Addressing mismatch in taxation of income from notified overseas retirement fund [Section 89A]
Cloud hosting services provided USA company to its Indian customers were not covered under the definition of ‘royalties’ as per India-US Tax Treaty as the agreement was to provide hosting services simpliciter and was not for the purpose of giving the underlying equipment on hire or lease and accordingly, it could not be said as royalty within the meaning of Explanation (2) to Section 9(1)(vi) as well as Article 12(3)(b) of the Indo-USA Data by AO and DRP.
In June, 2020, the US Trade representative initiated an investigation of India’s 2020 Equalisation levy (EL 2020) under the Section 301 of the Trade Act of 1974 to determine whether India’s EL 2020 is unreasonable / discriminatory and burdens / restricts U.S. commerce. The report was made public on 06 January, 2021.
SCA Hygiene Products AB (Essity Hygiene And Health AB) Vs DCIT (ITAT Mumbai) In order to decide whether or not the services rendered by the assessee fit the definition of ‘fees for technical services’, as applicable under the Indo Swedish tax treaty, the question that we must ask ourselves is not only whether the technical […]
Explore the tax implications as Sandvik AB challenges the characterization of Training fees, testing DTAA provisions, and its application in the ITAT Pune decision.
