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...
The ITAT remands BorgWarner’s case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation approach used for international transactions.
Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and key judicial interpretations.
Form No. 10F is a self-declaration for NRIs to claim benefits under DTAA when their Tax Residency Certificate lacks essential details.
Introduction In International Taxation, the concept of “make available” is very important to be looked into. It helps in determining whether the concerned fee paid for the services which are rendered cross-border would be classified as royalties or fee for technical services and would attract the withholding tax. Understanding how “make available” works helps the […]
Let’s talk about the tax benefits you can enjoy as an NRI in India and on Income earned outside India. Many NRIs don’t realize that the Indian tax system is pretty favorable, especially for those who mostly earn outside India.
Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.
Assessing foreign tax credit claim rejected due to Form 67 filing delay. The CIT(A) upheld disallowance for AY 2020-21. Tribunal reviews COVID-19 extensions.
ITAT Bangalore ruled on Deepak Shimoga Padmaraju foreign tax credit claim, denied due to late filing of Form 67 after the due date for the AY 2021-22.
ITAT Delhi rules that filing Form 67 is not mandatory for Foreign Tax Credit (FTC) claims, and procedural violations shouldn’t deny the right to FTC.
ITAT Chandigarh rules that the assessee cannot be denied Foreign Tax Credit (FTC) due to delay in filing Form No. 67.
