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...
India and USA have signed the Inter-Governmental Agreement (IGA) under FATCA in 2015. To enhance the effectiveness of information exchange and transparency, both the sides committed to establish, by January 1, 2017, rules requiring their Reporting Financial Institutions (RFIs) to obtain the Tax Identity Number (TIN) of each report able person having a report able account as of June 30, 2014 (pre- existing account).
In U.S.A., with the announcement of historical tax concessions for business, being reportedly released in the future, though the legal approvals have already been obtained, not a day passes when someone would not ask me what type of business he/ she may start in USA.
CbCR popularly known as Country-by-Country Reporting is a global transfer pricing (TP) compliance requirement under the transfer pricing laws of countries around the world. One of the major amendments in relation to the Indian TP Documentation and global compliance pertaining to the Multi National Enterprises (MNEs) Group vide Section 92D r.w.s. 286 of the Income-tax Act, 1961
Sonar Bangla resonates with Bengal as a historical entity and Bangladesh, both in Commerce and Cricket with its exceptional performance has enabled us to remember its gigantic growth. When one looks at any good ready-made in U.S.A. it is an open secret that Bangladesh with its visible presence in all brick and mortar shops has […]
This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. The purpose is to allow […]
This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices based on countries’ experiences of inter-agency co-operation in […]
International tax experts gathered today at the OECD in Paris to share experiences and identify best practices in the implementation of Tax Inspectors Without Borders (TIWB) programmes.
The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of 31 participating countries. The country profiles contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves.
The Central Board of Direct Taxes (CBDT), on 31st October, 2017, has notified the final set of Rules for Maintaining and Furnishing of Transfer Pricing Documentation under Income Tax Rules 1962. Objective: To introduce provisions for additional TP documentation and Country – by – Country reporting to implement the recommendations contained in the Organization for Economic Co-operation and Development (OECD)’s BEPS report on Action 13 The Draft Rules were issued on 6th October 2017 and kept open until 16th October 2017 for public & stakeholders comments and suggestions, if any, by electronically.
After the recent worldwide implementation of OECD’s recommendations to prevent Base Erosion and Profit Shifting (BEPS), another forum (The Platform for Collaboration on Tax) has released a discussion draft on The Taxation of Offshore Indirect Transfers – A toolkit (hereafter, referred as the toolkit) for public comments on 1 August, 2017.
