Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...
Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...
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 : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...
Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...
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...
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...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
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...
What are Permanent Establishments? The most important issue in the treaty based international fiscal law is the concept of Permanent Establishment (PE). All the models of conventions namely:
In case , one earns income which suffers tax outside India, the Income Tax Act has clear provision of relief from such double taxation. The relevant provision are contained in section 90 and section 91 of the I T Act. Section 90 is applicable for the cases when the tax has been paid in a country with which India has signed comprehensive double taxation avoidance agreements. There are Double Taxation Avoidance Agreements with as many as 79 countries .Comprehensive agreements are signed with these countries and Limited agreements with these countries.
Each family in India has at least one family which is resident outside India. Previously, the number of transactions between a resident and non-resident were limited but with growing number of family members now settling outside India, there is a tremendous increase in inflow and outflow of money between the two. This has made the tax department savvier and it has been increasingly important for both, resident as well as non-resident, to stay updated with fundamental rules and regulations.
The income tax rules and perks allowed to a Non-Residential Indian is drastically different from those applicable to resident Indians. NRI taxation in India is a constant matter of concern for the vast number of Indians living all over the world who have to send money to home and make investment planning for themselves and […]
When a non-resident sportsman comes to India for participating in any game or sport then a question arises which country has right to charge tax on such income earned by sportsmen by participating in game or sport and what are the tax implications on such income earned. Non-Resident Sportsmen means he is not the Citizen […]
Finance Act 2020 applicable for AY 2021-22 has altered the provisions for Indian Citizens and Persons of Indian Origin (PIO). Accordingly the period of 182 days specified in the Explanation for Indian citizen and person of Indian origin with total income other than income from foreign sources more than Rs. 15 Lacs, has been reduced to […]
Residential Status of an Individual under the Income Act,1961 as amended by Finance Bill 2020 Residential Status of an Individual determines the liability of an individual to tax in India according to the nature, source, accrual or receipt of Income. Section 6 of the Income Tax Act, 1961 lays down the criteria for determining the […]
Protocol Between The Government Of The Republic Of India And The Government Of The Republic Of Austria Amending The Convention For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income, Which Was Signed At Vienna On 8 November, 1999
Taxation of a person depends on his residential status in the country. Section 6 sub-section (1) of the Income Tax Act, 1961 provides the circumstances under which an INDIVIDUAL is said to be Resident in India. Once the INDIVIDUAL is said to be resident in India, then we need to find out if he qualifies […]
Reimbursement can be described as repayment of what has already been spent or incurred. Therefore, it should not be considered a reward or compensation for a service rendered.
