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international taxation

Latest Articles


Switzerland Suspends Unilateral MFN Clause Application in Tax Treaty with India

Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...

March 4, 2025 270 Views 0 comment Print

USA Taxation, 2024: Updated guidelines for Corporates

Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...

February 24, 2025 993 Views 0 comment Print

Delhi High Court Rules on Technical Services in International Logistics

Income Tax : CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a si...

February 21, 2025 246 Views 0 comment Print

USA Taxation 2024: Updated Guidelines for Individuals

Income Tax : Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn abo...

February 13, 2025 843 Views 1 comment Print

Income Tax Return Filing Guide for Proprietors in the USA

Income Tax : Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and pena...

February 9, 2025 1038 Views 0 comment Print


Latest News


CRS & FATCA: Tax Transparency & Disclosure of Foreign Assets & Income

Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...

January 3, 2025 888 Views 0 comment Print

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 846 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 366 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 89238 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 13236 Views 0 comment Print


Latest Judiciary


Mere operational links or subsidiary relationships do not confer PE status: Delhi HC

Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...

February 24, 2025 471 Views 0 comment Print

CPC Erred in denying Loss Carry-Forward to Company Eligible for Extended Due Date U/s. 92E: ITAT Ahmedabad

Income Tax : CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of In...

February 22, 2025 333 Views 0 comment Print

IT support payments not taxable as FTS due to failure of ‘make available’ test under India-UK DTAA: ITAT Delhi

Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...

February 9, 2025 276 Views 0 comment Print

Carried forward losses cannot be set-off against exempt capital gains under DTAA

Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...

February 8, 2025 456 Views 0 comment Print

Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC

Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...

January 29, 2025 639 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 3309 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 984 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 660 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 2997 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 4644 Views 0 comment Print


Salient features of Country-By-Country Report & Master File rules

November 2, 2017 963 Views 0 comment Print

The salient features of the Country-By-Country Report and Master File rules are as under: The threshold for the Country-By-Country Report is total consolidated group revenue of Rs. 5,500 crore or more.

India notifies provisions of DTAA/ Protocol entered with New Zealand

November 2, 2017 807 Views 0 comment Print

Agreement between the Government of the Republic of India and the Government of the Government of New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes – Notification No. 93/2017 – Income Tax

CBDT notifies rules for Country-By-Country Report and Master File rules

October 31, 2017 7149 Views 0 comment Print

Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-

CBDT extends due date for filing of Country-by-Country Report for 2016-17 to 31.03.2018

October 25, 2017 26574 Views 3 comments Print

Circular No. 26/2017 : Order under section 119 of the Income-tax Act, 1961 in respect of extension of due date for filing of Country-by-Country Report for reporting accounting year 2016-17

TDS deductible on Remittance to Google Ireland by Google India

October 23, 2017 3033 Views 0 comment Print

A division bench of the Bengaluru ITAT, on Tuesday held that the distribution fee paid by Google India to Google Ireland for use of its Ad words programme is taxable in India as royalty under the provisions of the Income Tax Act, 1961.

Comparison of U S Tax System Vs Switzerland Tax system

October 11, 2017 4218 Views 0 comment Print

According to Swiss Tax Conference, Swiss tax system’s development is historical in nature rather than a rational or theoretical one. A humbling statement of the noble body, indeed. With Federal tax administration, 26 Cantons and 2,250 communes venturing to have a pie in the tax collections of the great nation, mostly known in history for its beauty, great role in world wars and its cheese, liquor or beautiful cows, Switzerland, obtained its tax system in Helvetic period (1798 -1803).

Switzerland – Corporate Tax Overhaul

September 9, 2017 702 Views 0 comment Print

Switzerland’s Federal Council on 6th September initiated a consultation on a new proposal to reform the Swiss corporate tax system, known as Tax Proposal 17 or TP 17. A steering committee charged with preparing a new plan for tax reform presented its objectives and recommendations, recently.

Taxability of Non Resident Indian

September 4, 2017 18837 Views 0 comment Print

Based upon a set of specific guidelines and directives, it can be ascertained if a person is actually an NRI. If his/her income in India through aspects like capital gains from investments in shares, mutual funds, property rental and term deposits exceed the basic exemption limit as defined in the Income Tax Act, he/she would have to file a tax return.

U S Taxation – S Corporation – Useful information to be learnt and cherished

August 19, 2017 3072 Views 0 comment Print

What is a S Corporation? Quoting directly from irs.gov, our well known American federal government website for income tax purposes, “S corporations are corporations that elect to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.”

U S Taxation Vis-a-Vis Israeli Taxation: Interesting comparison

August 12, 2017 1284 Views 0 comment Print

When the Indian Prime Minister visited Israel recently and eulogies were written about Israel, my thought process needed more research on the tax aspect of Israel Vis – a – Vis U S taxation since both have been intertwined since its creation and a large number of Israelis do have twin citizenship from both the countries. For an Indian professional, it is important to know the current tax system in Israel so that when he would visit it as an expert engineer, scientist, capitalist or collaborator on defense projects, he is well prepared for his asset/wealth/income creation. It is not unusual to compare Indian brain with the best ones from Israel since both stimulate curious queries from others about their brilliance though both have no comparison in any other thing except their glorious civilizations.

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