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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 114648 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 455015 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 121902 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


NRI Taxation in India

January 20, 2022 24726 Views 1 comment Print

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 […]

Japanese taxation: Latest developments – 2021

January 15, 2022 2556 Views 0 comment Print

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 […]

How to File Self-Employment Tax in the UK?

January 6, 2022 1746 Views 0 comment Print

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 […]

Relief under Double Taxation Avoidance Agreement

January 6, 2022 8121 Views 0 comment Print

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 […]

South Korean taxation – Individual tax

January 3, 2022 3672 Views 0 comment Print

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 […]

Korean taxation: Evolution over the decades

December 28, 2021 3192 Views 0 comment Print

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 […]

Income tax – United Kingdom (UK)

December 20, 2021 9840 Views 0 comment Print

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 […]

Scheme of tax treaties limits the rights of taxation either to residence or to source jurisdiction

December 15, 2021 3222 Views 1 comment Print

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 […]

Application of MFN Clause of Tax Treaty

December 10, 2021 10599 Views 0 comment Print

Government of one country enters into an agreement with the Government of another country or a specified territory for (i) Granting of relief in respect to double taxation (ii) Avoidance of double taxation (iii) Exchange of information (iv) Recovery of income tax. Such agreement is called a Double Taxation Avoidance Agreement (DTAA). Often with the […]

Royalty received under BREW Operator agreement not taxable under India-US DTAA

November 28, 2021 1197 Views 0 comment Print

Qualcom Technologies Inc. Vs DCIT (ITAT Delhi) ITAT held that Considering the assessment order of the AO wherein he has followed the findings given in earlier assessment years and considering the fact that the same agreement is being carried on since A.Y.2005-06, we do not find any reason in differing with the view taken by […]

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