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international taxation

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Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 546 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 690 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 786 Views 0 comment Print

Taxation – The Game of Life – Transfer Pricing & International Taxation

Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...

June 2, 2024 852 Views 0 comment Print

Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...

May 27, 2024 426 Views 0 comment Print


Latest News


Representation to Simplify & Automate TRC Issue Process for Indian Companies

Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...

June 22, 2024 198 Views 0 comment Print

Format of Declaration of no PE in India and Form No. 10F

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 ...

May 8, 2023 67416 Views 0 comment Print

What is Filing Of 1042 Form?

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...

September 28, 2022 11595 Views 0 comment Print

UK Suspends Tax Co-Operation With Russia

Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...

March 24, 2022 399 Views 0 comment Print

ICRICT Open letter to G20 Heads of State and Government

Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...

October 12, 2021 702 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

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...

July 15, 2024 432 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

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...

July 8, 2024 267 Views 0 comment Print

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 327 Views 0 comment Print

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 345 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 Views 0 comment Print


Latest Notifications


CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...

March 19, 2024 1986 Views 0 comment Print

CBDT notifies Tax Information Exchange Agreement: India-Samoa

Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...

February 7, 2024 828 Views 0 comment Print

Income Tax Agreement Between India & Saint Vincent for information Exchange

Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...

November 1, 2023 594 Views 0 comment Print

DTAA between India and Chile notified by CBDT

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...

May 3, 2023 2298 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4191 Views 0 comment Print


CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

March 19, 2024 1986 Views 0 comment Print

Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and changes in taxation laws.

Understanding Small Business Tax: What You Need To Know

March 19, 2024 2955 Views 0 comment Print

Understanding small business tax obligations is a fundamental part of running a successful enterprise. At its core, these obligations revolve around accurately reporting income and expenses to the appropriate tax authorities, which in turn determines the amount of tax owed by the business. Small businesses must navigate through various types of taxes including income tax, […]

Key Provisions and Implications of India-USA Tax Treaty

March 18, 2024 3933 Views 1 comment Print

Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxation of incomes, and DTAA benefits.

Comparative analysis of Mutual agreement Procedure & Advance pricing agreement

March 16, 2024 747 Views 0 comment Print

Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their effectiveness, compliance, and applicability in resolving transfer pricing disputes.

The New UK Taxation Policy on ‘Non-domiciled’ residents

March 13, 2024 555 Views 0 comment Print

Learn about the UK’s plan to abolish the non-domiciled tax rule after 225 years, its implications for Indians, and the new residence-based taxation policy effective from April 2025.

Action 13 of BEPS Action Plan on Transfer Pricing Documentation

March 7, 2024 564 Views 0 comment Print

Explore the comprehensive requirements of Action 13 of the BEPS Action Plan on transfer pricing documentation, including local file, master file, and country-by-country reporting. Learn about implementation thresholds and India’s incorporation of these standards.

All about Form 10F and its Filing Procedure

March 5, 2024 7617 Views 2 comments Print

Learn the essentials of Form 10F filing for non-residents seeking DTAA benefits in India, including required documents, filing process, and online submission.

Receipts from Software Sale to Indian Entities Not Taxable under India-Singapore DTAA: ITAT Delhi

March 4, 2024 648 Views 0 comment Print

Detailed analysis of Finastra International Financial Systems PTE Ltd. Vs ACIT(International Taxation) case where ITAT Delhi ruled that software sales to Indian entities are not taxable under Article 12(3) of India-Singapore DTAA.

Tax treaty benefit cannot be denied for Fraud mobile number: ITAT Mumbai

March 4, 2024 552 Views 0 comment Print

In a landmark decision, ITAT Mumbai rules in favor of Abu Dhabi Investment Authority, stating that a fraud mobile number cannot deny tax treaty benefits. Full text of the order included.

Payments for marketing services not taxable as FTS: ITAT Bangalore

March 4, 2024 819 Views 0 comment Print

Delve into the detailed analysis of DCIT Vs AD2PRO Media Solutions Pvt. Ltd. case where marketing services rendered by a US entity in India were deemed not taxable, offering insights into tax benefits.

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