Follow Us:

international taxation

Latest Articles


Benefit to Non-Residents under Income Tax Act, 1961

Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...

July 3, 2026 114642 Views 0 comment Print

​International Business- Income Tax Sections to be remembered

Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...

June 30, 2026 18923 Views 1 comment Print

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 455009 Views 28 comments Print

Why Your Indian Subsidiary Abroad Might Be Triggering Tax Residency You Never Signed Up For?

Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...

June 25, 2026 432 Views 0 comment Print


Latest News


CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 2793 Views 0 comment Print

CRS & FATCA: Tax Transparency & Disclosure of Foreign Assets & Income

Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...

January 3, 2025 2094 Views 0 comment Print

Budget 2024: New Rules for Including Foreign Taxes in Total Income

Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...

July 24, 2024 1587 Views 0 comment Print

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 906 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 121899 Views 0 comment Print


Latest Judiciary


ITAT Deletes AMP TP Adjustment as No International Transaction Existed

Income Tax : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...

June 28, 2026 129 Views 0 comment Print

Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC

Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...

June 20, 2026 114 Views 0 comment Print

ITAT Partly Allows TP Appeal, Revises Comparable Selection for ALP Determination

Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...

June 17, 2026 246 Views 0 comment Print

No DAPE Where Distributors Act on Principal-to-Principal Basis ITAT Delhi

Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...

March 12, 2026 438 Views 0 comment Print

Interconnect Service Charges Not Royalty: Karnataka HC Dismisses Appeal

Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....

December 10, 2025 549 Views 0 comment Print


Latest Notifications


India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1269 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1797 Views 0 comment Print

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 4563 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 1464 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 933 Views 0 comment Print


Income from supply of CAS & middleware products not falls under ‘royalty’

September 27, 2022 921 Views 0 comment Print

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.

Expat Tax in India

September 22, 2022 2229 Views 0 comment Print

Navigating Expat Tax in India made easy. Learn about the tax rules, rates, and exemptions for expats working in India.

Section 206AA cannot have overriding effect on DTAA

September 19, 2022 2526 Views 0 comment Print

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 […]

Preserving and Applicability of Arm’s Length Principle

September 14, 2022 1881 Views 0 comment Print

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.

Foreign Tax Credit: A Bird’s Eye View

September 13, 2022 2295 Views 0 comment Print

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.

Section 195 not applies to payment not in the nature of FTS to Non-Resident not having PE in India

September 5, 2022 1857 Views 0 comment Print

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.

Not declaring swimming pools to avoid tax in France – Al to Detect Swimming Pools

September 4, 2022 1725 Views 0 comment Print

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.

Pricing Methods to detect Related Parties’ Transactions

August 30, 2022 3057 Views 0 comment Print

Discover the significance of pricing methods in detecting related party transactions. Learn how multinational companies reduce tax liabilities through progressive pricing.

Organization for Economic Cooperation and Development (OECD)

August 27, 2022 2025 Views 0 comment Print

Understanding the role of the Organization for Economic Cooperation and Development (OECD) in international taxation and transfer pricing.

Grandfathering clause under India – Mauritius Tax Treaty

August 19, 2022 8367 Views 0 comment Print

Grandfathering clause means an old provision in law continues to apply on certain existing situations corresponding to new provisions which has been introduced to apply to all the future situations.

Search Post by Date
July 2026
M T W T F S S
 12345
6789101112
13141516171819
20212223242526
2728293031