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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 255 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 990 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 450 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 633 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 2988 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 4641 Views 0 comment Print


Understanding the Taxation of Offshore Services in India

September 15, 2024 1485 Views 0 comment Print

In this article, we will analyse position of composite contract that is being taken into account regarding taxability of offshore services in India.

An Insight Into Tax Avoidance, Backed By Recent Developments

September 12, 2024 1128 Views 0 comment Print

Explore the legal boundaries of tax avoidance, recent rulings, and the evolving jurisprudence in India with key cases like Vodafone shaping fiscal policies.

Benefit to Non-Residents under Income Tax Act, 1961

September 5, 2024 110538 Views 0 comment Print

Income-tax Act contains special provision for taxability of a non-resident person, including a foreign company. A few benefits are extended to non-residents by these provisions, inter-alia, global income of a non-resident is not taxable in India, various interest income are not taxable in India and so forth. This document gives a brief introduction to those provisions which provides certain benefits to a non-resident.

​International Business- Income Tax Sections to be remembered

September 3, 2024 16511 Views 1 comment Print

Relevant provisions of Indian Income Tax Act that non-residents must comply with when setting up a business in India, and residents dealing with non-residents.

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

September 3, 2024 39613 Views 1 comment Print

Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications for dividends, interest, royalties and technical services.

Countrywise Withholding tax rates / Chart as per DTAA

September 3, 2024 420977 Views 28 comments Print

Withholding tax rates for dividends, interest, royalties and Fee for Technical Services in different countries. Understand how taxes vary for different recipient companies.

Payments for Online Learning Platform Access Not Taxable as FTS under India-USA DTAA

September 3, 2024 1476 Views 0 comment Print

ITAT Delhi rules Coursera’s income from Indian customers not taxable as Fees for Technical Services (FTS) under India-USA DTAA. A key decision for online platforms.

Income Tax Provisions applicable to non-residents

August 28, 2024 62419 Views 6 comments Print

Understanding how residential status affects income taxability in India. Learn about the different residential statuses and their tax implications.

India-Mauritius: Implications of Principal Purpose Test

August 19, 2024 798 Views 0 comment Print

India and Mauritius have amended the DTAA, adding a principal purpose test (PPT) rule to close tax loopholes and align with global norms. Explore its impact on FPI and FDI.

Tax Avoidance in UK: Key Strategies and Regulations

August 13, 2024 591 Views 0 comment Print

Explore legal strategies used in tax avoidance in UK, including judicial doctrines, TAARs, GAARs, DOTAS, and the role of HMRC. Learn about key regulations.

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