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...
In this era of accelerated globalisation, cross border tax interactions have been high on the political agenda of the multinational entities (‘MNE’). Globalisation, inter-alia brings in inter-country mobility of corporate presence, employees, technology, intellectual property, know-how etc. With increased cross border movement of such elements comes tax controversies, most controversial one being cross border profit […]
Tax Information Exchange Agreements (TIEA) are agreements developed by the Organization for Economic Co-operation and Development (OECD). The purpose of the TIEAs was mainly to reduce the harmful tax practices. They also seek to facilitate international cooperation with the help of exchange of information surrounding tax matters such as details about tax evaders who hide money in offshore places/tax havens which fall under banking secrecy jurisdictions such as countries like Cayman Islands, and Argentina etc. British Virgin Islands, Bermuda, Bahamas, Cayman Islands, and Argentina etc.
The income of a non-resident Indian (NRI) earned in India is taxable. Whether a person will be classified as NRI or not will depend on the number of days he or she has stayed in India and the quantum of income earned. Tax on an individual’s income depends on the source of such income and […]
Let me wish you ‘Akemashite omedetou gozaimasu. (formal): あけましておめでとうございます’ a Happy New Year in Japanese. Let us proceed with our learning of the latest developments in Japanese taxation. Due to initiation of Japanese taxation in our earlier articles in an exhaustive manner, let me narrate the steps taken by Jetro, Japan external trade organization (web […]
Independent work is quite difficult, and it involves a lot of liability. You should care for your workers, handle your cash, settle your assessments, and present your government forms. Whether or not independently employed, people are needed to pay personal assessment paying little heed to their type of revenue. Nonetheless, independently operated workers often neglect […]
QUESTION: The Income Tax Act, 1961 provides for taxation of a certain income earned in India by Mr. X a non-resident. The DTAA ,which applied to Mr. X provides for taxation of such income in the country of his residence. Examine ,is Mr. X is liable to pay tax on such income earned by him […]
In continuation of my writing on the taxation of the top 25 GDP rated countries, South Korea with its unique income tax for individuals deserves special treatment. I got the latest information from the web site of National Tax Service, (NTS) the government owned one to help with tax information. Proper reference is given at […]
In our tribute to top 25 GDP nations of the world, South Korea has shown a remarkable story to be written in golden letters. Like any Asian country, this lateral part of the century 2000 along with the next one naturally belongs to this quality obsessed nation. Luckily, I came across its taxation in a […]
I am on a series of articles to explain basically the income tax of top 25 GDP countries which invite most of the Indian exporters/experts from India who help these countries to grow, prosper, and distribute wealth among those associated with them. It is time for United Kingdom economy to get the priority. Income tax […]
ITO Vs Rajeev Suresh Ghai (ITAT Mumbai) It is always useful to bear in mind the fact that, on the first principles, the trigger for taxation of an income in a source jurisdiction is either the economic activity or the linkage of an income with that jurisdiction, and that in the absence of such a […]
