Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
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 held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
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 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...
The complexities of UAE VAT regime and the Federal Tax Authority or FTA’s current targeting for tax evasion and avoidance means tax disputes are increasingly arising. There will be instances wherein you disagree with an assessment or decision that is made by the local tax authority. If you are in complete disagreement with a certain […]
HIGHLIGHTS OF THE UNION BUDGET-2021 -22- Tax proposals- International Taxation – 1. Addressing mismatch in taxation of income from notified overseas retirement fund [Section 89A]
Cloud hosting services provided USA company to its Indian customers were not covered under the definition of ‘royalties’ as per India-US Tax Treaty as the agreement was to provide hosting services simpliciter and was not for the purpose of giving the underlying equipment on hire or lease and accordingly, it could not be said as royalty within the meaning of Explanation (2) to Section 9(1)(vi) as well as Article 12(3)(b) of the Indo-USA Data by AO and DRP.
In June, 2020, the US Trade representative initiated an investigation of India’s 2020 Equalisation levy (EL 2020) under the Section 301 of the Trade Act of 1974 to determine whether India’s EL 2020 is unreasonable / discriminatory and burdens / restricts U.S. commerce. The report was made public on 06 January, 2021.
SCA Hygiene Products AB (Essity Hygiene And Health AB) Vs DCIT (ITAT Mumbai) In order to decide whether or not the services rendered by the assessee fit the definition of ‘fees for technical services’, as applicable under the Indo Swedish tax treaty, the question that we must ask ourselves is not only whether the technical […]
Explore the tax implications as Sandvik AB challenges the characterization of Training fees, testing DTAA provisions, and its application in the ITAT Pune decision.
DDIT Vs Mitsui & Co. Ltd. (ITAT Delhi) Learned DR contended that MIPL is economically dependent on assessee company as major revenue of MIPL is from assessee company. We are of the view that this per se cannot be ground to hold that MIPL is a Dependent Agent. For invoking this clause, first one of […]
Determination of place of effective management (POEM) – ABOI and other principles 1. Introduction to POEM:- Section 6(3) of the Income-tax Act, 1961 (the Act), prior to its amendment by the Finance Act, 2015, provided that a company is said to be resident in India in any previous year, if it is an Indian company […]
PCIT Vs Yum Restaurants India Pvt. Ltd (Delhi High Court) The Court sets aside the impugned order and the corresponding orders of the AO/TPO and the DRP as regards the issue of AMP expenses and remands the issue concerning the determination of the existence of an international transaction between the Assessee and its AE involving […]
What is Madrid Protocol? The Madrid Protocol is an international system for obtaining trademark protection for many countries and/or regions using a single application. Protection (an ‘International Registration’) can only be obtained for countries and regions which have joined the system (member countries), and these are listed below. An international treaty that allows a trademark […]
