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...
Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-
Circular No. 26/2017 : Order under section 119 of the Income-tax Act, 1961 in respect of extension of due date for filing of Country-by-Country Report for reporting accounting year 2016-17
A division bench of the Bengaluru ITAT, on Tuesday held that the distribution fee paid by Google India to Google Ireland for use of its Ad words programme is taxable in India as royalty under the provisions of the Income Tax Act, 1961.
According to Swiss Tax Conference, Swiss tax system’s development is historical in nature rather than a rational or theoretical one. A humbling statement of the noble body, indeed. With Federal tax administration, 26 Cantons and 2,250 communes venturing to have a pie in the tax collections of the great nation, mostly known in history for its beauty, great role in world wars and its cheese, liquor or beautiful cows, Switzerland, obtained its tax system in Helvetic period (1798 -1803).
Switzerland’s Federal Council on 6th September initiated a consultation on a new proposal to reform the Swiss corporate tax system, known as Tax Proposal 17 or TP 17. A steering committee charged with preparing a new plan for tax reform presented its objectives and recommendations, recently.
Based upon a set of specific guidelines and directives, it can be ascertained if a person is actually an NRI. If his/her income in India through aspects like capital gains from investments in shares, mutual funds, property rental and term deposits exceed the basic exemption limit as defined in the Income Tax Act, he/she would have to file a tax return.
What is a S Corporation? Quoting directly from irs.gov, our well known American federal government website for income tax purposes, “S corporations are corporations that elect to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.”
When the Indian Prime Minister visited Israel recently and eulogies were written about Israel, my thought process needed more research on the tax aspect of Israel Vis – a – Vis U S taxation since both have been intertwined since its creation and a large number of Israelis do have twin citizenship from both the countries. For an Indian professional, it is important to know the current tax system in Israel so that when he would visit it as an expert engineer, scientist, capitalist or collaborator on defense projects, he is well prepared for his asset/wealth/income creation. It is not unusual to compare Indian brain with the best ones from Israel since both stimulate curious queries from others about their brilliance though both have no comparison in any other thing except their glorious civilizations.
Since the inclusion of royalty as a form of income attracting deemed taxation, by the Finance Act 1976, the gradually expanding ambit of this definition, have led to seemingly incessant tax controversies on the subject. Divergent views by the Indian tax courts on characterization of remittances to non-residents for usage of software, exploitation of intellectual property rights denied certainty in interpretation of the simultaneously evolving tax provisions.
The issue of global taxation of Indians residing in USA, or residing in India but being a US reportable person, requires comprehensive understanding of the following: US tax laws which are governed by IRS; Specific regulations under FATCA which covers foreign assets; Provisions of FEMA in India; Guidelines by the Reserve Bank of India from […]
