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...
It was held that where the software is purchased across the counter as shrink proof software, then it is not akin to royalty both under the Income Tax Act or the DTAA. The Tribunal held that since the definition of ‘royalty’ has not been amended under DTAA,
Author in this article discusses proposed taxation regime by CBDT on Profit attribution to a PE in India and recommendations thereon. It is definitely a welcome step as it will reduce the quantum of litigation.
Government of the Republic of India and the Government of Republic of the Marshall Islands, desiring to facilitate the exchange of information with respect to taxes have agreed as follows:
India and United States of America signed an inter- governmental agreement for exchange of country- by –country (CbC) reports on March 27, 2019. This enabled both the countries to exchange CbC reports filed by the ultimate parent organizations of multinationals in respect of jurisdictions, pertaining to the years commencing on or after January 1, 2016. […]
With almost 16 million people, the foreign population of India is the largest. Interestingly, the maximum number of these Non-Resident Indians (NRIs) have their own Bank Accounts, they invest good amounts in various sectors, such as Bank Deposits, Shares, House Property. They are free to increase their assets. But at the same time, it brings […]
The India-Hong Kong DTAA enters into force from 30th November, 2018. The same would be effectively applicable from 01st April, 2019. Accordingly, the benefit of the provisions of the DTAA can be claimed in respect of the income derived in any year starting from April 1, 2019. The companies engaged into cross-border transactions with Hong […]
With the start of the new financial year 2019-20, following are some of the changes that can affect your financial planning as a few changes related to income tax, GST and international taxation came into effect from 01st April, 2019: A) Income Tax Following are the changes under Income-tax law applicable from April 1, 2019: 1. […]
Ever wondered, when Virat Kohli hits centuries on cricket grounds situated outside India, which country shall have right to tax his income arising from such play? Or when the audience outside India gets Goosebumps listening to the voice of Arijit Singh, how the said income shall be taxed? The taxation rights of Artistes and Sports […]
Indo-UK DTAA must be read as forming part of Indo-Spain DTAA as well and, therefore, the payment made by the assessee to the Spanish company for fabric testing would not constitute fee for technical services and consequently, section 195 of the Act has no application to such a receipt.
TAXATION OF INTEREST ON DEPOSITS MADE BY NON RESIDENTS IN INDIAN BANKS AND ON LOANS GIVEN BY FIIs/FPIS TO INDIAN CORPORATES Q.1 Whether interest income of non resident individual with regard to the deposits made in any bank in India is taxable in India ? Ans. Yes, the interest income of non resident individual whether […]
