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...
Mumbai ITAT rules capital gains on a foreign company’s share sale are non-taxable in India under Article 13(5) of the India-Singapore DTAA. TRC is conclusive proof.
SC confirmed disposal test in Hyatt PE case, ruling that deep operational control and access to hotel premises constituted a PE for UAE firm under India-UAE DTAA, making income taxable in India.
MTD for ITSA mandates digital record-keeping and quarterly updates for self-employment and property income. Effective April 2026 for 50k+ income.
ITAT Delhi rules DigiCert Inc’s receipts from Indian resellers for digital security certificates aren’t royalty or FTS. It’s a non-taxable sale of a copyrighted article.
Fees for Technical Services (FTS) in India’s tax law conflict with DTAAs that include the ‘make available’ clause. This clause requires the transfer of know-how for FTS taxation, leading to extensive litigation over interpretation and applicability.
Karnataka High Court upheld its earlier decision that payments for interconnect services to non-resident telecom operators do not constitute “Royalty” under the Income Tax Act.
SC held Hyatt’s oversight of Indian hotels created a fixed-place PE, broadening disposal and continuity tests under the India–UAE tax treaty.
The Karnataka High Court dismissed an appeal by the Income Tax Department, ruling that payments to Syna Media for software licenses are not taxable as royalty, citing the Supreme Court’s precedent in the Engineering Analysis case.
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.
