Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how IRS audits are initiated and conducted to verify tax return accuracy. It highlights taxpayer duties, righ...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
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 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 Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
Income Tax : Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Ar...
Income Tax : ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefi...
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...
Article explains What is Double Taxation Avoidance Agreement (DTAA), and how DTAA helps, types of relief under DTAA, Benefits of DTAA, How to claim DTAA benefits in India and What are the documents required for an NRI to claim DTAA benefit. What if you currently reside in the UK, have invested in India, and are […]
Income from supply of CAS and middleware products to indian customers, does not fall under ‘royalty’ as defined under Section 9(l)(vi) of Income Tax Act, 1961 and Article 12(3) of India- Swiss DTAA.
Navigating Expat Tax in India made easy. Learn about the tax rules, rates, and exemptions for expats working in India.
CIT International Taxation Vs Air India Ltd. (Delhi High Court) Whether ITAT has erred in holding that the rate of deduction of tax in the case of a non-resident who does not have a PAN and whose case does not lie in the exceptions laid down in Sub-Section 7 of Section 206AA of the Act […]
While it may not be perfect, the member countries of the OECD focus have a tendency that the arm’s length principle should govern the judgment of transfer pricing between associated enterprises.
Understand the concept of Foreign Tax Credit (FTC) and its significance in mitigating double taxation on income earned outside India. Explore how Double Taxation Avoidance Agreements (DTAA) play a crucial role in preventing double taxation. Learn about the process of claiming FTC, including filing Form 67 and providing necessary documentation. Gain insights into the relevant details and conditions associated with FTC, ensuring a transparent and justifiable taxation system for Indian residents with foreign income.
Assessee was not having any permanent establishment in India and was providing the service only from Singapore and therefore the provisions of Section 195 of the Act are not applicable.
Property tax in France is based on the rental value of the property and any addition to the property like permanent (not temporary) has to be declared before tax authorities within 90 days, since property tax is based on rental value, so any improvement will increase the rental value of property resulting in increased property tax.
Discover the significance of pricing methods in detecting related party transactions. Learn how multinational companies reduce tax liabilities through progressive pricing.
Understanding the role of the Organization for Economic Cooperation and Development (OECD) in international taxation and transfer pricing.
