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...
In this article, I have covered the need and relaxations provided by the Central Government on Residential Status in Circular no. 11 dated May 8, 2020. As per the provisions of section 6 of the Income-tax Act, 1961 ‘period of stay’ of an individual is used to determine the residential status of individual taxpayers. Ordinarily, […]
Recent clarification issued by CBDT – Lockdown time period will not be counted in the determination of residential status of NRIs for the FY 2019-20 Considering the impact of Covid 19 and amidst the situation of lockdown and suspension of international flights CBDT has recently issued Circular No 11 of 2020 dated 8 May 2020 […]
Lockdown Period Not to Be Counted For Determining Residency Status of NRIS, Foreign Nationals ; CBDT clarifies in respect of residency under section 6 of the Income-tax Act, 1961 Finance Minister Nirmala Sitharaman on Friday (8th May, 2020) allowed discounting of prolonged stay period in the country for determining the residency status, to provide relief to […]
Technically speaking there is no concept such as International taxation. But for our convenience we say, the international aspects of income tax laws of a particular nation as international taxation.
In India, the status of tax residency of an individual is determined based on his number of days of stay in India during a financial year. Every year, various Non-Resident Individuals (‘NRI’) visit India to manage their family affairs/investment in India. Such individuals plan their stay in India in a manner that they remain non-resident in India for tax purposes.
A person of Indian origin (PIO) is a person of Indian origin or ancestry who was or whose ancestors were born in India or nations with Indian ancestry but is not a citizen of India and is the citizen of another country. A PIO might have been a citizen of India and subsequently taken the citizenship of another country.
CBDT issues Circular No. 11 of 2020 and excluded period of forced stay in India from 22nd March, 2020 to 31st March, 2020 in computation of residential status in India for Financial Year 2019-20. Circular No. 11 of 2020 F. No. 370142/18/2020-TPI, Government of India Ministry of Finance Department of Revenue Central Board of Direct […]
International Tax Perspective – Part II : Place of Effective Management (POEM) Establishments – Corporate Tax Residency Introduction Businesses are currently dealing with a multitude of issues as a result of the measures taken to stop the global spread of the COVID-19. One aspect that might not currently feature at the top of the list […]
What are Permanent Establishments? The most important issue in the treaty based international fiscal law is the concept of Permanent Establishment (PE). All the models of conventions namely:
In case , one earns income which suffers tax outside India, the Income Tax Act has clear provision of relief from such double taxation. The relevant provision are contained in section 90 and section 91 of the I T Act. Section 90 is applicable for the cases when the tax has been paid in a country with which India has signed comprehensive double taxation avoidance agreements. There are Double Taxation Avoidance Agreements with as many as 79 countries .Comprehensive agreements are signed with these countries and Limited agreements with these countries.
