Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
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 : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...
Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
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...
The provision relating to Residential Status in India is governed by Section 6 of Income Tax Act, 1961. Necessity to determine residential status is significant to determine total income of taxpayers in India. Generally, taxpayers are classified as Residents or Non-Residents.
When software itself is not taxable, the training and related activities concerned with utilization & installation cannot be held to be FTS.
Explore Argentina’s tax system, including individual income tax, social security contributions, wealth tax, corporate tax, incentives, and more.
Article 1 of United Nations Model Convention on Income and Capital (the Model) provides scope and application of Convention. It outlines the persons and entities to which the Model applies, as well as the types of taxes to which it is applicable.
Form W-8BEN is a document used by foreign individuals and other such entities to claim a reduced rate of, or exemption from, U.S. tax withholding on certain types of income they receive from U.S. sources.
ITAT Bangalore held that the amount paid by Google India Private Limited (GIPL) to M/s. Google LLC (US) towards seconded employees doesn’t come under the purview of FTS (Fees for Technical Services) or FIS (Fees for Included Services) under the Income Tax Act or under DTAA.
Delaware Franchise Tax is an annual tax imposed by the state of Delaware on businesses that have been incorporated or organized in Delaware. The tax is based on the value of the company’s authorized shares, which is the total number of shares that the company is authorized to issue, as well as the par value of those shares.
ITAT Ahmedabad held that in case of payments to non-resident, when PAN of non-resident payee is not available, TDS is to be deducted at the rates applicable in respective Tax Treaties.
ITAT Mumbai held that that the interest paid by the Indian branch-PE to the head office-GE is not taxable in India in terms of India-France DTAA.
Section 9 of Income Tax Act, 1961, relates to the income deemed to accrue or arise in India. Income is considered as ‘accruing or arising in India’ if it is earned in India or if it is received in India or if it is received/accruing or arising in any other manner in India.
