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international taxation

Latest Articles


Global Tax Avoidance: Double Irish, Dutch Sandwich

Income Tax : Explore how MNCs used the Double Irish & Dutch Sandwich strategy to avoid taxes and the global efforts made to close these loophol...

April 15, 2025 516 Views 0 comment Print

Analysis of Impact & Effectiveness of Bilateral Investment Treaties

Income Tax : Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within ...

March 20, 2025 432 Views 0 comment Print

Switzerland Suspends Unilateral MFN Clause Application in Tax Treaty with India

Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...

March 4, 2025 324 Views 0 comment Print

USA Taxation, 2024: Updated guidelines for Corporates

Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...

February 24, 2025 1122 Views 0 comment Print

Delhi High Court Rules on Technical Services in International Logistics

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...

February 21, 2025 324 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 1344 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 990 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 858 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 414 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 93423 Views 0 comment Print


Latest Judiciary


Exempt LTCG Under India-Mauritius DTAA Not Adjustable Against Taxable Losses: ITAT Mumbai

Income Tax : It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing t...

April 22, 2025 63 Views 0 comment Print

Planning, HR, Legal & IT Support Not Taxable as FTS Under India-USA DTAA, Citing ‘Make Available’ Test

Income Tax : ITAT Delhi rules Crocs Inc.'s service income not taxable in India under DTAA, as services did not "make available" technical knowl...

April 20, 2025 399 Views 0 comment Print

Receipts from Passenger System Solutions not taxable as FTS in India: ITAT Mumbai

Income Tax : ITAT Mumbai rules Sita USA's airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2...

April 15, 2025 195 Views 0 comment Print

Capital Gains on Mutual Funds by Singapore Resident Not Taxable in India: ITAT Mumbai

Income Tax : ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore ...

April 15, 2025 1476 Views 0 comment Print

Capital Gains on Mutual Fund Units Not Taxable in India for Singapore Resident Under DTAA: ITAT Mumbai

Income Tax : ITAT Mumbai allows tax exemption on capital gains for NRI under India-Singapore DTAA, rejecting AO's classification of mutual fund...

April 4, 2025 1320 Views 0 comment Print


Latest Notifications


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 3411 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 1017 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 708 Views 0 comment Print

DTAA between India and Chile notified by CBDT

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...

May 3, 2023 3084 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4761 Views 0 comment Print


Importance of Disclosing Foreign Income & Assets in ITR

November 27, 2024 3798 Views 0 comment Print

Accurate disclosure of foreign assets and income in ITR is essential to avoid penalties. Revised returns can be filed by December 31, 2024, for A.Y. 2024-25.

Royalty on Advertisement Hoardings cannot be equated with imposition of Tax

November 3, 2024 1023 Views 0 comment Print

Supreme Court rules that royalty on advertisement hoardings by Patna Municipal Corporation cannot be equated with a tax. Case clarifies royalty vs. tax distinction.

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

November 1, 2024 252 Views 0 comment Print

Delhi High Court judgment on Cadence Design’s appeal against the ITAT order regarding transfer pricing comparables. Key findings on ALP determination and comparability.

KPO Service Provider Not Comparable to ITES for Transfer Pricing Benchmarking

October 14, 2024 492 Views 0 comment Print

Delhi HC ruling clarifies that KPO service providers aren’t comparable to ITES providers for benchmarking international transactions.

No Interest Adjustment for AE if No Interest Charged from Unrelated Third Party

October 11, 2024 636 Views 0 comment Print

Delhi High Court upholds ITAT ruling in PCIT vs Global Logic India Ltd., addressing deferred payments and international transactions under Section 92B of the IT Act.

From Double Taxation to Treaty Shopping: Unfolding Saga of India-Mauritius DTAA

October 7, 2024 1260 Views 0 comment Print

Explore the India-Mauritius DTAA’s impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fostering genuine investments.

A Tax Haven in the Desert: Why Indians are flocking to Dubai?

September 30, 2024 2523 Views 0 comment Print

A question that was shooting up recently, was: Why are so many Indians going to Dubai? After a detailed research and analysis I understood that there is a rush by the rich and business enterprises from different parts of the world to the United Arab Emirates (UAE) or Dubai where costly livings, advanced infrastructure as well as an outstanding location attracts.

Decoding Complexities of Non-Resident Taxation

September 27, 2024 864 Views 0 comment Print

Understand key tax provisions for non-residents in India, including residential status determination, taxable income types, and implications under Indian law.

Taxation issues faced by RNOR individuals in India

September 25, 2024 1482 Views 0 comment Print

Explore tax complexities faced by RNOR individuals in India, including foreign income taxation, DTAAs, and recent changes in tax rates impacting compliance.

Aggregation vs. Segregation Approach in Benchmarking International Transactions

September 25, 2024 579 Views 0 comment Print

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.

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