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...
PCIT Vs Yum Restaurants India Pvt. Ltd (Delhi High Court) The Court sets aside the impugned order and the corresponding orders of the AO/TPO and the DRP as regards the issue of AMP expenses and remands the issue concerning the determination of the existence of an international transaction between the Assessee and its AE involving […]
What is Madrid Protocol? The Madrid Protocol is an international system for obtaining trademark protection for many countries and/or regions using a single application. Protection (an ‘International Registration’) can only be obtained for countries and regions which have joined the system (member countries), and these are listed below. An international treaty that allows a trademark […]
ACIT Vs Mitsui & Co. Ltd. (ITAT Delhi) The facts in brief are that the assessee-company is incorporated in Japan and had a subsidiary in India, Mitsui India Pvt. Ltd. (MIPL). In India, assessee has undertaken several projects in connection with big natural installment and power projects during the relevant year through its project office. […]
Avoidance of Permanent Establishment (PE) status of Non-Residents are made through various arrangements. Company structures their business in way that status of PE can artificially be avoided. The definition of permanent establishment included in tax treaties is therefore crucial in determining whether a non-resident enterprise must pay income tax in another jurisdiction. Strategies used to […]
Smit Singapore Pte Ltd. Vs DCIT (ITAT Mumbai) Assessee had received charges on account of time charter services rendered by its vessel ‘Smit Borneo‘ along with the crew to Leighton India Contractor Pvt. Ltd., and not for allowing the latter the ‘use‘ or ‘right to use‘ of industrial, commercial, or scientific equipment, the same therein […]
GCO Technologies Centre Private Ltd. Vs ITO (ITAT Mumbai) We have deliberated at length on the aforesaid issue under consideration and are unable to persuade ourselves to subscribe to the projection of the aforesaid comparable company viz. M/s Cather Consultancy Services Pvt. Ltd by the assessee as a profit making company during the financial year […]
The issue under consideration is whether DRP is correct in considering the Liaison Office (LO) and Land Earth Station (‘LES’) constitutes a permanent establishment (PE) in India?
Background Material of Diploma in International Taxation (2020 – Fifth edition) containing: -International Tax – Transfer Pricing -International Tax – Practice (Part I & II) Tax laws in India are becoming more and more complex. Globalization of economies, signing and review of free trade agreements, increase in the number of cross border transactions, mergers, acquisitions, […]
Technical Guide on BEPS Action Plans and Multilateral Instrument (MLI) – 2020 – First edition Considering the issue that profits should be taxed where the economic activities take place and no profit should suffer double taxation, in September 2013, the Finance Ministers of the G20 nations came out with a comprehensive action plan on […]
Basics of International Taxation – 2020 (fourth edition) – (Earlier known as Aspects of International Taxation – A Study) International Taxation due to its dynamic and ever changing nature has always been a complex subject not only to study but to practice. Due to increase in cross border transactions, mergers and acquisitions, e-commerce, capital mobility […]
