Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...
Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...
Income Tax : CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a si...
Income Tax : Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn abo...
Income Tax : Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and pena...
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 : 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 : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...
Income Tax : CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of In...
Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...
Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...
Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...
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...
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.
DDIT Vs Mitsui & Co. Ltd. (ITAT Delhi) Learned DR contended that MIPL is economically dependent on assessee company as major revenue of MIPL is from assessee company. We are of the view that this per se cannot be ground to hold that MIPL is a Dependent Agent. For invoking this clause, first one of […]
Determination of place of effective management (POEM) – ABOI and other principles 1. Introduction to POEM:- Section 6(3) of the Income-tax Act, 1961 (the Act), prior to its amendment by the Finance Act, 2015, provided that a company is said to be resident in India in any previous year, if it is an Indian company […]
