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...
Target marketing on overseas social media or automated advertising platforms not taxable as ‘Royalty’ In a major relief to taxpayers availing online marketing services from social media platforms like Facebook, the Bangalore bench of Income Tax Appellate Tribunal (ITAT) recently ruled in the case of Urban Ladder Home Décor Solutions Pvt. Ltd. Vs ACIT that […]
We often come across with cases where there has been double taxation on the same income both from source and resident countries. Typically from an India tax perspective, in case of ‘resident and ordinarily resident’ (ROR) having investments abroad, this scenario is quite common. In order to mitigate such double taxation implications, Section 90 of […]
As the world moves increasingly towards economic integration and globalization there is a lot of cross border trade, investment and business which will only increase as more and more developing and least developed countries open up their borders for more business with the international community.
Bombay Chartered Accountant’s Society has made a representation to CBDT Chairman and draw his attention towards the difficulties faced, in recent times, by resident taxpayers, in claiming Foreign Tax Credit (FTC) for their income abroad, while filing their return of Income in India. Full Text of their representation is as follows:- Bombay Chartered Accountant’s Society […]
Technology plays a vital role in today’s world making our daily lives simpler. From medical diagnoses to business operations, from communication to education, everything seems impossible without technology. This pandemic has evidenced the same. Life would have come to stand still without it. But nothing stopped. Technology has infiltrated every aspect of our lives, changing […]
Non-residents are subject to tax in India with respect to the income accrued/ deemed to accrue in India or received/ deemed to be received in India as per the provisions of the Income Tax Act, 1961 (‘Act’). While the international tax landscape is seeing a lot of changes in form of OECD BEPS Pillar 1 […]
21st century world largely operates under a Global Economic System. International Business is the buzz all around & businesses are not confined to boundaries. It involves cross border transactions both in goods and services. Conducive International Business Environment is imperative for multinational companies to operate and perform. In order to promote cross border trade, the […]
Inflow Technologies Private Limited Vs ACIT (ITAT Bangalore) The assessee, as a part of share purchase agreement, during the business structuring had given a corporate guarantee to one of its group supplier CISCO for supplies made to its AE (Inflow Singapore). According to the assessee, it did not intend to get any remuneration for the […]
India has gained an ill-reputation regarding its retrospective taxation laws in the past decade, especially due to the amendments made to Section 9 by the Finance Act, 2012. Retrospective operation of this amendment gave rise to three notable international tax disputes, namely the Vodafone International Holdings BV case, the Cairn Energy PLC case, and the […]
The Double Taxation Avoidance Agreement (DTAA), inter alia, provide rules and mechanisms for allocation of taxing rights amongst the treaty partners; avoidance of economic and juridical double taxation; and resolution of taxation not in accordance with the treaty through the Mutual Agreement Procedure (‘MAP’). MAP is an inbuilt and alternate tax dispute resolution mechanism available to the taxpayers under the DTAAs. It is […]
