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...
CBDT has released the synthesised text for India-Latvia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. LATVIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA […]
CBDT has released the synthesised text for India-Belgium tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA […]
CBDT has released the synthesised text for India-Malta tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA […]
MLI synthesised text for India-Luxembourg tax treaty-This document was prepared jointly by the Competent Authorities of India and Luxembourg and represents their shared understanding of the modifications made to the Agreement by the MLI.
In India, companies are taxed on their income according to their residential status. A company with residential status in India will be taxed on its global income whether earned in India or outside India whereas a non resident company will be taxed only on income received, accrued or arise in India.
The Agreement between the Government of the Republic of India and the Government of Brunei Darussalam for the exchange of information and assistance in collection with respect of taxes (hereinafter referred to as the Agreement), was signed in New Delhi, India on 28th of February, 2019. The Agreement has been notified in the Gazette of India (Extraordinary) on 9th of March 2020.
International Tax Bulletin Foreign Tax & Tax Research Division JANUARY 2020 VOL.1, ISSUE 1 LATEST DEVELOPMENTS ON TAXATION OF DIGITALISED ECONOMY In the last week of January 2020, the meeting of G20/OECD Inclusive Framework (IF) was held in Paris to decide the future course of action for finalising the time lines and action plan for […]
ICAI Analysis of Tax Proposals made by Union Budget 2020 related to International Taxation HIGHLIGHTS OF THE UNION BUDGET-2020-21 Tax proposals- International Taxation 1. Exemption in respect of certain income of wholly owned subsidiary of Abu Dhabi Investment Authority and Sovereign Wealth Fund [Section 10(23FE)] Exemption proposed to be provided to income of a specified […]
Press Information Bureau Government of India Cabinet 12-February-2020 Cabinet approves protocol amending the Agreement between India and Sri Lanka for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi, has approved the Signing and Ratification of the […]
Budget 2020:Amendment for providing attribution of profit to Permanent Establishment in Safe Harbour Rules under section 92CB and in Advance Pricing Agreement under section 92CC Section 92CB of the Act empowers the Central Board of Direct Taxes (Board) for making safe harbour rules (SHR) to which the determination of the arm’s length price (ALP) under […]
