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...
ITAT held that Satellite transmission services provided by USA based company in India could not be brought to tax by treating the same as royalty income and amendment to the Income Tax Act, 1961 with a retrospective or prospective effect, cannot be read in a manner so as to extend the operation to the terms of international treaty.
EXISTING AND EMERGING FRAMEWORK OF TAX PLANNING AND INTERNATIONAL TAXATION (LATEST AND SIMPLIFIED) Tax Planning assumes significance in a growing economy like India. We need concrete Tax Planning measures to strengthen our industries and savings. It is not tax evasion. Tax planning from salaried persons, pensioners and Corporate houses are needed to avoid tax costs […]
Taxation of Non Residents in India Non Residents (hereafter referred to as NR) having a source of income in India are required to comply with the Indian tax laws which has certain beneficial provisions specific to them for facilitating their participation in the Indian economy. A NR, for the purposes of Income-tax Act, is used […]
CBDT has released the synthesised text for India- Serbia and Montenegro 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 AND THE CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC […]
American business to watch for these monumental changes include corporations, S Corporations, partnerships like LLCs and sole proprietorships. I gleefully agree that as a business owner or self-employed individual one may like to review tax reform sections that may affect the bottom line of the business.
CBDT has released the synthesised text for India-UAE tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI.
Synthesised text of MLI and Convention between Government of Japan and Government of Republic of India for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income.
In our Transfer Pricing world, the OECD has duly acknowledged the fact that the business environment has evolved due to change in technology and digitalization. The efforts of OECD to walk hand in hand with the ongoing evolution of technology is visible from its work in Action 1 – Digitalisation, Business Models and Value Creation, where it is trying to justify its underlying principle need to align transfer pricing outcome with value creation
With the increase in the complexity and growing enterprise landscape, a number of IT companies engage in creation of databases and soft wares and have also entered in the business of data collection and data systemisation. In return, these vendor companies charge annual subscription fee that can be defined as the amount of money the vendors charge on a consequential basis for providing periodic access to their database and software.
Let us understand the concept of Interest in the context of cross-border taxation with the help of an example. When an Indian Company borrows money by way of Loan from a person resident of Germany, the Indian Company will pay Interest at agreed rate to such Non-resident. Now, the question arises, which country gets the right to tax such Interest Income of the Non-resident?
