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 definition of a technical service under Kenya tax is a bit complex. This is for a number of reasons. First, technical services overlap in many instances with payments for royalties. This would arise where someone supplies software installation services, user training services and similar services. You may read more about this possible interaction on […]
DIT Vs Jeans Knit Pvt. Ltd. (Karnataka High Court) From the agreement executed by the assessee with the non-resident company, it is evident that the non-resident company is required to inspect the quality of fabric and other accessories in accordance with the sample approved by the assessee and coordinate with the suppliers to ship the […]
The mutual exchange procedure was invoked in the Kenya France DTA in the case analysed below. This is an interesting remedy that taxpayers in Kenya should adopted regularly. This is especially taxpayers making payment to a country which Kholds a Doubel Tax Agreement with Kenya. Kenya has 15 effective Double Tax Agreements. This includes Kenya […]
Nations around the world engage in many kinds of agreements related to financial matters. Such treaties and agreements prove to be beneficial for the residents (individuals as well as business entities) of those countries who are active parties in the agreement. They can provide a tax credit, tax exemptions, and an overall cut in the […]
A. Introduction The rules on interpretation of tax legislation are important to understand as they play a key role in the outcome of tax disputes in Kenya. Chinese companies operating in Kenya would greatly benefit from this knowledge. The thesis considers several High Court decisions on the issue. It then considers possible queries that arise […]
With the incessant global growth, the relevance of Permanent Establishment (PE) in international taxation has become paramount. In simpler terms, the expression ‘Permanent Establishment’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
In this dynamic era, the brick and mortar business models are turning digital and Multi-National Companies (MNCs) are effectively operating out of various jurisdictions without having a physical presence. From a taxation perspective, it is way more challenging when the value creation, income generation and the adjoining taxability cut across various countries. The Organization for […]
Since past two-decade, software industry has undergone tremendous technological changes and accordingly such industry has emerged to be one of the fastest growing industry worldwide. India being a developing country provides ample opportunities for Multi-national Enterprises (MNEs) to expand their business in India. The technological advancement has acquainted such MNEs to expand with negligible physical […]
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 […]
