Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
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 held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
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 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...
In this article, author will discuss the implication of Hong Kong and India both completing their relevant procedures in respect to double tax avoidance agreement (DTAA). Further it will be analyzed in detail meaning of various dates in respect to India – Hong kong DTAA and date from which it can be used for remittance to Hong Kong Residents.
India being a G20 Country is committed to implement the minimum standards laid down in the Base Erosion and Profit Shifting (BEPS) Project. One of the minimum standards that every participating jurisdiction has to achieve is to ensure a Transparency Framework for spontaneous exchange of rulings under BEPS Action 5.
A Company is a separate legal entity from its shareholders. Under S.2 (7) of the Income Tax Act, all entities can be shareholders. For example, sometimes Companies themselves are shareholders in other companies and draw Inter Corporate Dividends from the other.
The Finance Act, 2012 expanded the scope of the term International Transaction thereby giving the clarity as to what the legislature meant or rather deemed fit to be International Transaction and consequential amendments were also made to other connected sections of Transfer Pricing in the Income-tax Act, 1961.
Moet Hennessy India Pvt Ltd Vs ACIT (ITAT Delhi) In the present case, no new facts have emerged and all the facts brought to record, during the course of the assessment proceedings, do not indicate legally sustainable basis for coming to the conclusion that there was an internal transaction in respect of AMP expenses incurred […]
Germany has been changing income tax laws since 1964 to keep pace with the changing industrial scene in the world. Its complex income tax structure and progressive tax rates are explained in this article. With the opening up of their economy for working professionals from software super power like India, Indian professionals have started learning in German universities and started working in high tech companies. This article would open up the tax system in Germany for these brilliant young professionals. Your kid may be one of them to do business or work in one of their high- tech industries
Samsung Electronics Co. Ltd. Vs. DCIT (Int. Taxation)- ITAT Delhi Analysis of the Samsung Case on the Determination of a Permanent Establishment (PE) for Services Provided by Seconded Employees of a Korean Parent to Its Subsidiary in India This article examines the ruling of the Delhi Bench of the Income Tax Appellate Tribunal (ITAT or […]
ICAI released an e-book on Taxation of Non-Residents based on the law as amended by the Finance Act, 2018. The book contains following topics- Chapter 1. Residential Status Chapter 2. Income Deemed to Accrue or Arise in India Chapter 3. Income not to be included in the total income Chapter 4. Presumptive Taxation Chapter 5. […]
Onus is heavily upon the revenue to establish that that assessee’s activity had crossed the threshold period of 12 months and hence constitutes PE in India in terms of Article 5(2)(g) so as to tax the receipts in India as per Article 7.
CBDT notifies protocol amending India-Portuguese DTAA vide Notification No. 43/2018- Income Tax Dated: 11th September, 2018
