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...
An analysis of how direct taxes are triggered globally, exploring key taxable events, common complications, and the role of jurisprudence in India, the US, and other countries.
A country-by-country analysis of indirect tax systems, detailing how taxable events trigger liability and the complexities of compliance across jurisdictions.
An overview of the compliance challenges Indian MNEs and tax authorities face due to OECD Pillars 1 and 2, covering profit allocation, minimum tax, and incentive impacts.
A summary of the UAE Corporate Tax Law’s definitions for related parties under Article 35 and the arm’s length principle in Article 34, including transfer pricing methods.
The ITAT Mumbai hears arguments on whether the MLI can be applied to deny tax treaty benefits to an Irish firm without a separate protocol, in a case involving aircraft leasing.
A summary of how residential status, determined by stay duration in India, affects the taxability of an individual’s income, including rules for residents, non-residents, and companies.
A summary of key Indian court rulings on royalty taxation, covering software, satellite transmission, and equipment leasing, and highlighting the precedence of tax treaties.
What counts as “being in business” in India? When does advisory work cross the line into a taxable presence? The Hyatt International ruling is more than just another tax dispute. It is a clear reminder that in international taxation, substance prevails over form. The Supreme Court upheld the Delhi High Court’s finding that Hyatt International […]
Denial of DTAA benefits to UAE resident over capital gains on debt mutual funds. The case examines whether ‘liable to tax’ requires actual tax payment.
Supreme Court clarifies the scope of PE in India, ruling that Hyatt International’s operations are taxable under Indian law.
