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international taxation

Latest Articles


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 261 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 993 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 246 Views 0 comment Print

USA Taxation 2024: Updated Guidelines for Individuals

Income Tax : Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn abo...

February 13, 2025 843 Views 1 comment Print

Income Tax Return Filing Guide for Proprietors in the USA

Income Tax : Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and pena...

February 9, 2025 1038 Views 0 comment Print


Latest News


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 888 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 846 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 366 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 89238 Views 0 comment Print

What is Filing Of 1042 Form?

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...

September 28, 2022 13236 Views 0 comment Print


Latest Judiciary


Mere operational links or subsidiary relationships do not confer PE status: Delhi HC

Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...

February 24, 2025 471 Views 0 comment Print

CPC Erred in denying Loss Carry-Forward to Company Eligible for Extended Due Date U/s. 92E: ITAT Ahmedabad

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...

February 22, 2025 333 Views 0 comment Print

IT support payments not taxable as FTS due to failure of ‘make available’ test under India-UK DTAA: ITAT Delhi

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...

February 9, 2025 276 Views 0 comment Print

Carried forward losses cannot be set-off against exempt capital gains under DTAA

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...

February 8, 2025 453 Views 0 comment Print

Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC

Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...

January 29, 2025 636 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 3309 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 984 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 660 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 2997 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 4644 Views 0 comment Print


Direct Tax & International Tax Perspective – Covid 19 Impact- FAQs

April 10, 2020 1275 Views 0 comment Print

Direct Tax & International Tax Perspective–Part I Income Tax Returns 1. Whether there is any extension of due dates in filing the belated returns for the Financial Year 2018-19? Answer: Yes, due date income tax return for Financial Year 2018-19 was 31st March 2020. The Ministry of Finance, vide Press Release dated 24.03.2020 has extend the due […]

Transfer of funds from NRO A/c. to NRE A/c. or Remittance Abroad

April 5, 2020 31353 Views 8 comments Print

If you are a Non-Resident Indian (NRI) or a Person of Indian Origin (PIO), you can open, hold and maintain (without permission from the Reserve Bank of India) following types of accounts with an authorised dealer in India i.e. a bank authorised to deal in foreign exchange: a) Non-Resident (Ordinary) Rupee Account – NRO Account […]

Taxability of Rental Income received by a Non- Resident Individual (NRI)

April 4, 2020 10641 Views 6 comments Print

Every person who has relocated out of India, has at one point or another faced issues with respect to taxability of his income earned in India. In this article we shall be looking at the aspects that cover taxability of rental income earned from property situated in India for an individual who has been assessed […]

What should NRI (Non resident Indians) take from Budget 2020?

April 2, 2020 2964 Views 0 comment Print

Finance Act, 2020 has come up with some landmark amendments in the Income Tax Act, 1961 in relation to taxation of income for Non-resident Indians making it more difficult for such people to maintain their ‘Non-resident’ tag so as to keep their foreign income out of the Indian Income Tax applicability. Indian citizens having a […]

Definition of Capital Assets being Securities for the purposes of Non Residents followed by Gist of board circular

April 2, 2020 2460 Views 0 comment Print

Analysis of Definition of Capital Assets being Securities for the prospective of Non Residents including Foreign Institutional Investors as per Section 2(14) of the Income Tax Act, 1961 read with certain important circulars and letters issued by the Central Board of Direct Taxes.

Foreign Companies and Permanent Establishment (PE)

April 1, 2020 43698 Views 6 comments Print

With this article, we would like to explicate the concept of Foreign Companies and PE in light of Indian Income Tax Act provisions. Foreign Companies ♠ Foreign company means a company which is not a domestic company, i.e. a company registered outside India in any other foreign country. [Section 2(23A)] ♠ The Foreign Company may […]

Residential Status as per Finance Act 2020

March 31, 2020 26877 Views 4 comments Print

Modification of residency provisions In order to bring prevent tax abuse the Finance Act, 2020  modified the Residency Provision. According to the un-amended Section 6, an individual is said to be resident in India in any previous year, if he— (a) is in India in that year for a period or periods amounting in all […]

Finance Act 2020 Analysis of International Taxation related amendments

March 31, 2020 9663 Views 0 comment Print

Article mainly explains Amendments vide Finance Act, 2020 relating to Residential Status, Amendment Removing Dividend Distribution Tax and Impact thereof, Incorporation of MLI and Introduction of Equalization Levy on E-Com Operators.

Determination of Residential Status of Individual under Income Tax Act

March 28, 2020 66726 Views 11 comments Print

Introduction: Determination of the residential status under Income Tax Act plays a vital role in to determine whether a person comes under the tax net or not. Section 6 of the Income Tax Act deals about the concept of resident for Income tax purposes. Finance Act 2020 dated 23.03.2020 amends Section 6 of the Income […]

Japan Income Tax, 2019 – New Revelations

March 27, 2020 1905 Views 0 comment Print

Japan is in the process of shifting its goal post for Olympic Games 2020 to 2021. But its income tax details for 2019 are already out and helping millions to understand, and implement by filing tax returns at point of need. Yes, let us understand Japan Income Tax, 2019 in details for a common man. […]

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