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international taxation

Latest Articles


Tax Avoidance in UK: Key Strategies and Regulations

Income Tax : Explore legal strategies used in tax avoidance in UK, including judicial doctrines, TAARs, GAARs, DOTAS, and the role of HMRC. Lea...

August 13, 2024 330 Views 0 comment Print

UAE Transfer Pricing Compliance Dates

Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....

July 31, 2024 753 Views 0 comment Print

FBAR Submission Guide: U.S. Taxation & Reporting Rules

Income Tax : Understand FBAR requirements for U.S. taxpayers. Learn about reporting foreign financial accounts, penalties for non-compliance, a...

July 21, 2024 534 Views 0 comment Print

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 660 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 840 Views 0 comment Print


Latest News


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 693 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 234 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 70740 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 12336 Views 0 comment Print

UK Suspends Tax Co-Operation With Russia

Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...

March 24, 2022 402 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...

July 15, 2024 588 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...

July 8, 2024 309 Views 0 comment Print

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 372 Views 0 comment Print

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 381 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 507 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 2241 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 870 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 609 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 2403 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 4248 Views 0 comment Print


Does constitution of “Service PE” entail physical presence of foreign personnel in host country?

July 7, 2017 3588 Views 0 comment Print

Permanent Establishment (PE) is the fundamental criterion under the tax treaties for taxation of foreign company’s business income in India. A permanent establishment of a foreign company is typically regarded as a virtual extension or taxable presence of such foreign company in the host country, similar to that of an independent legal entity in such country. A PE of a foreign company is required to maintain books of accounts as per the normal accounting principles in the host country, besides undertaking tax compliances alike an independent legal entity.

POEM – Tracking the evolution of new Residency Norm

July 5, 2017 2307 Views 0 comment Print

Place of Effective Management (PoEM) has been one of the most deliberated aspects under the Indian Income Tax regime since its introduction vide Finance Act, 2015, especially for Indian transnational groups.

U S Taxation Vs Canadian Income Tax for individual- a Study

June 29, 2017 1323 Views 0 comment Print

During my recent visit to Southern India, particularly, Tamil Nadu, my family doctor having many covenanted degrees in Medicine from Canada, mentioned about the high income/other tax rates in Canada and also their social commitments to take extra care of the welfare of their citizen.

Draft Notification on foreign company resident in India U/s. 115JH

June 15, 2017 1728 Views 0 comment Print

CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961

Revision of Safe Harbour Rules: A Positive Thought!

June 12, 2017 3081 Views 0 comment Print

In India, new transfer pricing rules were introduced in 2002. Since then, the number of cases identified for audit and the transfer pricing adjustments locked up in disputes have increased tremendously. In order to reduce the increasing number of transfer pricing audits and prolonged disputes

Safe Harbour Rules- Eligible International Transactions

June 9, 2017 4098 Views 1 comment Print

Prabhakar K S  [Ilaya Azwan] The Central Board Of Direct Taxes (CBDT) Vide Notification No. 46/2017 Date 7th June, 2017 Notifies Revised List Of ‘Eligible International Transactions’ For Transfer Pricing Safe Harbour Rules. Sl. No. Eligible International Transactions Circumstances   01 Software Development Services Operating Profit Margin declared by the eligible assessee from the EIT in […]

India Signs MLC to Prevent Base Erosion and Profit Shifting

June 8, 2017 1398 Views 0 comment Print

Finance Minister Shri Arun Jaitley signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting at Paris on 7th June, 2017 on behalf of India.

U S Taxation – Questions Green card holders or U S Citizens wanted to ask from India

June 6, 2017 3303 Views 1 comment Print

1. What are my responsibilities as a green card holder if I have been absent from the United States for a long period of time? 2. I was a long-term resident of the United States prior to surrendering my green card. What is my U.S. tax filing obligation?

Value Added Tax (VAT) in France – A lively discussion

June 6, 2017 1722 Views 0 comment Print

The areas covered under VAT in France includes continental France, Corsica, the Principality of Monaco, territorial waters, the continental shelf and the départements of Guadeloupe, Martinique and La Réunion.

U S Taxation VS other countries’ taxation (China and France) – A comparative study

June 1, 2017 1956 Views 0 comment Print

Nothing invigorates one than a small chat when one returns from other countries. Being a CPA from USA, I invariably invoke the recent tax challenges taken up by the American government for reducing its taxation rate for its tax payers. Just looking at other countries’ position on basic taxation rates itself is an exhaustive exercise. But the motivation to undertake this write up came from a young professional who returned from New York along with myself in an Air India flight. Obviously, at a young age, he has lived in China, France, and others who would give him visa in future, Japan, in particular

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