Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how IRS audits are initiated and conducted to verify tax return accuracy. It highlights taxpayer duties, righ...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
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 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 Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
Income Tax : Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Ar...
Income Tax : ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefi...
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...
COVID 19, now named a pandemic, came as an unwanted visitor, merged with as many people as possible unknowingly and then tens of millions of the whole world including the whole ecosystem just succumbed to its pressure. But how many of us know the extraordinary steps taken by the tax administrators of various nations without […]
Edenred Pte Ltd. Vs DDIT (ITAT Mumbai) In the instant case, the appellant has received fees for referral services/other services of Rs.39,94,209/- from Surf Gold in the year under consideration. It is relevant to mention here that as per the India-Singapore DTAA, the services in the nature of managerial, technical or consultancy nature are taxable […]
Ireland And Others V European Commission (General Court of the European Union, Luxembourg) EU General Court annuls decision of European Commission and rules in favour of Apple by holding no Irish State Aid The General Court, Luxembourg (GC), the second highest judicial body in EU finally rendered its long-awaited judgment in the cases of Ireland […]
Are you irregular in filing US Individual tax returns? Current guidelines to solve them It is once or many times US Citizen or permanent residents (Green Card Holders) ring me about the instances of their passport being held up by American embassy officials or being asked about their filing US Tax returns for global income […]
A. WHAT IS DOUBLE TAXATION OF INCOME? When the same income is taxed more than once, it creates double taxation. This may be due to when a person is taxed in more than one country for the same income which he had earned, leads to double taxation. Countries have started entering into Double Taxation Avoidance […]
The mutual agreement procedure is a well-established means through which tax administrations consult to resolve disputes regarding the application of double tax conventions. This procedure, described and authorized by Article 25 of the OECD Model Tax Convention, can be used to eliminate double taxation that could arise from a transfer pricing adjustment. Article 25 sets […]
This article introduces a fresh perspective to the taxation of offshore indirect transfer of immovable property. It argues that such offshore indirect transfer can be taxed under the specific anti-abuse provisions of Section 2(47)(vi) of the Income-tax Act 1961 as they stood prior to the retrospective amendments brought into the Act through the Finance Act 2012.
Though erstwhile rules 44G and 44H were in existence for a number of years, detailed information regarding MAP processes and guidance on issues related to such processes were not available in a comprehensive and consolidated manner.
In Transfer pricing proceedings, corporate guarantee given by assessee to its foreign AE is always disputed by the department as an international transaction and adjustment determined on the basis of average bank guarantee rates. However, in number of judgements by tribunal and HC, the stand of the department is overruled and relief granted to the assessee.
One of the biggest problems in today’s international tax regime is the loss of billions of global corporate income tax revenues through the use of legal tax avoidance strategies. ‘Base Erosion and Profit Shifting (BEPS) is a phrase commonly used to refer to tax avoidance strategies that taxpayers use to shift their profits from high […]
