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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 255 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 990 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 450 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 633 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 2988 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


UAE Transfer Pricing Compliance Dates

July 31, 2024 1203 Views 0 comment Print

Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023. Learn more now!

Budget 2024: New Rules for Including Foreign Taxes in Total Income

July 24, 2024 846 Views 0 comment Print

From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent double deductions.

FBAR Submission Guide: U.S. Taxation & Reporting Rules

July 21, 2024 738 Views 0 comment Print

Understand FBAR requirements for U.S. taxpayers. Learn about reporting foreign financial accounts, penalties for non-compliance, and filing procedures.

Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

July 15, 2024 1053 Views 0 comment Print

ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory.

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

July 13, 2024 966 Views 0 comment Print

Explore India’s income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal developments.

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

July 8, 2024 360 Views 0 comment Print

For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or consultancy services might not fulfill unless such services are directly connected with a PE.

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

July 4, 2024 471 Views 0 comment Print

Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Detailed analysis and full judgment inside.

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

June 25, 2024 1992 Views 0 comment Print

Understand the UAE’s transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure compliance with Article 36 requirements.

Representation to Simplify & Automate TRC Issue Process for Indian Companies

June 22, 2024 366 Views 0 comment Print

Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Learn more!

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

June 21, 2024 483 Views 0 comment Print

Explore the ITAT Hyderabad’s decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed analysis and conclusions provided.

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