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...
The inequality crisis remains unaddressed and out of control. Hundreds of millions of people are living in extreme poverty while large rewards go to those at the very top. In 2019, the world’s billionaires, only 2,153 people, had more wealth than the poorest 4.6 billion people combined, according to Oxfam. A new generation of inequalities […]
Finance Act, 2017 inserted a new Section 92CE in the Income-tax Act, 1961 with effect from 1st day of April, 2018 to provide for secondary adjustment by attributing income to the excess money lying in the hands of the associated enterprise.
Section 295(2) (ha) of the Income Tax Act, 1961 provides that the CBDT (Board) may make Rules for the procedure for granting of relief or deduction, as the case may be, of any income tax paid in any country or specified territory outside India, under Section 90 or Section 90A or Section 91, against Income – tax payable under the said Act.
Non-understanding of correct residential status creates a high buzz for persons residing outside India or the persons visiting foreign for most of the year. They remain confuse whether taxes are to be paid in India and quantum of such taxes
Who is a non resident under Income Tax Act, 1961? Non-resident is a person who is not a ‘resident’ as per the Income Tax Act, 1961. For detailed provisions related to residential status, reference may be made to TPI brochure titled “Determination of Residential status under Income-tax Act, 1961”. Income which are not included in […]
The CBDT has released the final rules through notification (N No. 3497(E) on preparation and filing of Master file by the Constituent Entity of an International group. The brief of the rules as notified and the documentation requirements as needed for the filing are summarized below:
The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your reference.
Tax havens create huge challenges before countries in terms of shifting of profits, flight of capital, hiding of unaccounted wealth & other assets of tax residents of countries and providing a safe haven for parking corruption proceeds from where it is ultimately laundered back into source countries.
In today’s globalised world, even officers posted outside the Commissionerate of International Taxation should have working knowledge about basics of International Taxation and the DTAAs. This article tries to develop a working guide to the officers on the issue of payment to non-residents.
Since its creation in 2015, ICRICT calls to stop the harmful race to the bottom in both corporate tax rates and the artificial shifting of corporate profits to low-tax jurisdictions by putting a floor to tax rates and attributing taxable profits to the jurisdictions where real economic activity takes place. We therefore welcome the ongoing […]
