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...
Aditya Khanna Vs DDIT (ITAT Delhi) The Income-tax in relation to any country includes Income-tax paid in any part of the country or a local authority. It applies to cases where in a federal structure a citizen is made to pay federal Income-tax and also the State income tax. The Income-tax in relation to any […]
whether the Tribunal was correct in holding that the assessee is liable to be taxed at 10% in view of replacement of 15% with 10% of tax in Article 12 of the DTAA without taking into consideration that the modification of rate of tax by way of notification?
India issues comprehensive guidance on cross-border tax dispute resolution India on 7 August issued detailed guidance on the procedure for resolving cross-border tax disputes under the mutual agreement procedure (MAP) set out in India’s tax treaties with other nations. The guidance addresses critical issues that arise during the MAP process, benefiting not only taxpayers and […]
U.S. citizens and U.S. resident aliens will receive the Economic Impact Payment of $1,200 or $2,400 if they filed married filing jointly and if they are not a dependent of another taxpayer and have a work-eligible Social Security number with adjusted gross income up to: -$150,000 for married couples filing joint returns -$112,500 for head […]
The definition of a technical service under Kenya tax is a bit complex. This is for a number of reasons. First, technical services overlap in many instances with payments for royalties. This would arise where someone supplies software installation services, user training services and similar services. You may read more about this possible interaction on […]
DIT Vs Jeans Knit Pvt. Ltd. (Karnataka High Court) From the agreement executed by the assessee with the non-resident company, it is evident that the non-resident company is required to inspect the quality of fabric and other accessories in accordance with the sample approved by the assessee and coordinate with the suppliers to ship the […]
The mutual exchange procedure was invoked in the Kenya France DTA in the case analysed below. This is an interesting remedy that taxpayers in Kenya should adopted regularly. This is especially taxpayers making payment to a country which Kholds a Doubel Tax Agreement with Kenya. Kenya has 15 effective Double Tax Agreements. This includes Kenya […]
Nations around the world engage in many kinds of agreements related to financial matters. Such treaties and agreements prove to be beneficial for the residents (individuals as well as business entities) of those countries who are active parties in the agreement. They can provide a tax credit, tax exemptions, and an overall cut in the […]
A. Introduction The rules on interpretation of tax legislation are important to understand as they play a key role in the outcome of tax disputes in Kenya. Chinese companies operating in Kenya would greatly benefit from this knowledge. The thesis considers several High Court decisions on the issue. It then considers possible queries that arise […]
With the incessant global growth, the relevance of Permanent Establishment (PE) in international taxation has become paramount. In simpler terms, the expression ‘Permanent Establishment’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
