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international taxation

Latest Articles


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

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 546 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 690 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 786 Views 0 comment Print

Taxation – The Game of Life – Transfer Pricing & International Taxation

Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...

June 2, 2024 852 Views 0 comment Print

Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...

May 27, 2024 426 Views 0 comment Print


Latest News


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 198 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 67419 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 11595 Views 0 comment Print

UK Suspends Tax Co-Operation With Russia

Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...

March 24, 2022 399 Views 0 comment Print

ICRICT Open letter to G20 Heads of State and Government

Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...

October 12, 2021 702 Views 0 comment Print


Latest Judiciary


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

Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...

July 15, 2024 432 Views 0 comment Print

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

Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...

July 8, 2024 267 Views 0 comment Print

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

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 327 Views 0 comment Print

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

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 345 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 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 1989 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 828 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 594 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 2298 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 4191 Views 0 comment Print


Due date of furnishing audit report in case of international transactions extended to 30th November

March 17, 2012 2561 Views 0 comment Print

As per the existing provisions of the Income-tax Act, the report of audit under section 44AB is required to be furnished by 30th September of the assessment year. Section 139 was amended vide Finance Act 2011 to extend the due date of furnishing of return by the corporate assessees, who have undertaken international transactions, from 30th September to 30th November of the assessment year.

India Ratifies the Multilateral Convention on Mutual Administrative Assistance in Tax Matters

February 24, 2012 864 Views 0 comment Print

India had signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on 26th January, 2012. The Convention has been ratified by India by depositing the Instrument of Ratification as on 21st February, 2012. By this, India has become the first non-OECD, non-Council of Europe country to become a party to the Convention as amended by the 2010 Protocol

Greece signs international tax agreement to tackle tax evasion

February 24, 2012 288 Views 0 comment Print

Greece has signed the Convention on Mutual Administrative Assistance in Tax Matters, a multilateral agreement that was developed jointly by the Council of Europe and the OECD and that is open for signature to all countries. The Convention promotes international co-operation in the assessment and collection of taxes.

International Taxation – Witholding Tax Rates and provisions

February 5, 2012 2588 Views 0 comment Print

195. [(1)Any person responsible for paying to a non-resident, not being a company, or to a foreign company, any interest or any other sum chargeable under the provisions of this Act (not being income chargeable under the head “Salaries” shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier, deduct income-tax thereon at the rates in force :

No great ambiguity in international tax laws – IT official

June 4, 2011 588 Views 0 comment Print

The Income Tax department today said there is no great ambiguity in international tax laws and the Government wants to have more transparency in deals. There are issues…debatable issues, but there is no great ambiguity in international tax laws, Director General of Income Tax, International Taxation, R N Dash, said on the sidelines of a CII event here.

CBDT – Transfers / Postings of Additional/ Joint CITs in International Taxation and Transfer Pricing

May 10, 2011 995 Views 0 comment Print

CBDT Vide Order No. 81 of 2011 dated 9.5.2011, the CBDT has transferred & posted Additional/ Joint CITs in the Directorate of International Taxation & Transfer Pricing. Vide Order No. 82 of 2011 dated 9.5.2011, the CBDT has transferred & posted Deputy/ Assistant CITs.

ICAI Commences Registration for the Certificate Course on International Taxation – Hyderabad

April 28, 2011 7245 Views 0 comment Print

We are pleased to announce that the Committee on International Taxation of ICAI has decided to commence the next Batch of the Certificate Course on International Taxation in Hyderabad from Saturday 21st May, 2011.

Budget 2011- Govt may not raise taxes, try to streamline international tax

January 12, 2011 270 Views 0 comment Print

The government is likely to plug loopholes in international taxation to swell its kitty, since it does not have too many options to raise taxes in the upcoming Budget due to proposed rates in new direct and indirect tax regimes and high inflation. R

Advent of APA in TP regime

November 26, 2010 486 Views 0 comment Print

The arena of International taxation has always been quite complex as much as it has been exciting (for tax practitioners in particular). What with residency rules, PE provisions, TP regimes, 195 issues and DTAAs, in fact, it will be more exciting as

Direct Tax Code-2010 Proposed Changes in respect of international taxation

October 2, 2010 324 Views 0 comment Print

Income shall be deemed to accrue in India if it accrues, directly or indirectly through or from transfer of a capital asset situated in India. However, the income from the transfer by a non?resident of any share or interest in a foreign company would not be considered as income, wherein at any time in twelve months preceding the transfer, the fair market value of the assets in India, owned, directly or indirectly, by the company, represent at least fifty per cent of the fair market value of all assets owned by the company.

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