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 issue which is arising in the present appeal is whether there is DAPE. The Assessing Officer has alleged the existence of DAPE on account of alleged marketing activities undertaken by Indian entity on behalf of the assessee company.
Corporate India today serves global needs and brings in overseas income which is chargeable to Indian tax net as a resident of India. Flip side of this paves way for claim for taxes paid at foreign jurisdiction based on the source of income.
Introduction The Fiscal Policy is the government’s means to influence and regulate the economy by means of revenue and expenditure. The two main tools of fiscal policy are – Taxation (for raising revenue and is the major source of Income for government). Expenditure (on public welfare for achieving desirable social and economic goals) Types of […]
Dubai, a major business center in the Middle East has been treated as a tax haven for the Investors / Businessmen. The Taxation system is very satisfactory for the Businessmen and Investors. The corporate tax is set at a maximum rate in the oil and bank sectors in the Emirates. Taxation aspects for Companies in […]
Multilateral Instruments (MLI) is indeed the talk of the town in the world of International Taxation. Under the OECD*/G20 inclusive framework on Base Erosion and Profit Shifting (BEPS), more than 125 countries are collaborating to put an end to tax avoidance strategies that exploit the gap and mismatches in tax rules to avoid paying taxes.
Delaware, U.S.A., is one of the most tax-friendly states which attracts the maximum number of business entities to do the business with the most business-friendly policies. I get a maximum number of calls/inquiries about the individual tax/corporate tax or other tax-related matters. Though I have written the maximum number of articles on American Taxation, this […]
Whether the agent in India was a ‘Dependent Agent’ constituting a permanent establishment (PE) and the appellant was, therefore, liable to be taxed as per India UK DTAA?
Everyone is conversant with the proverb ‘Old wine in new bottles‘. On similar lines, the Finance Act, 2020 shifts the incidence of taxation of dividends in the hands of shareholders by abolishing the DDT regime. Under the new regime (effective 1 April 2020), the dividends earned by foreign shareholders are usually subject to a tax […]
Acquisition And Transfer of Immovable Property In India: FEMA and International Taxation Perspective ACQUISITION AND TRANSFER OF IMMOVABLE PROPERTY – A NRI or an OCI may acquire immovable property in India other than an agricultural land or farm house or plantation property. POI as a category is no longer eligible to acquire immovable property as […]
Withholding taxes u/s 195 in respect of transactions with Non-Residents has always been a bone of contention between Assessee and tax authorities. Though liability for deduction of TDS is clear in respect of some transactions like royalties, fees for technical services, interest etc.,
