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Latest Articles


Benefit to Non-Residents under Income Tax Act, 1961

Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...

July 3, 2026 114648 Views 0 comment Print

​International Business- Income Tax Sections to be remembered

Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...

June 30, 2026 18923 Views 1 comment Print

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 455015 Views 28 comments Print

Why Your Indian Subsidiary Abroad Might Be Triggering Tax Residency You Never Signed Up For?

Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...

June 25, 2026 432 Views 0 comment Print


Latest News


CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 2793 Views 0 comment Print

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 2094 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 1587 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 906 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 121902 Views 0 comment Print


Latest Judiciary


ITAT Deletes AMP TP Adjustment as No International Transaction Existed

Income Tax : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...

June 28, 2026 129 Views 0 comment Print

Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC

Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...

June 20, 2026 114 Views 0 comment Print

ITAT Partly Allows TP Appeal, Revises Comparable Selection for ALP Determination

Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...

June 17, 2026 246 Views 0 comment Print

No DAPE Where Distributors Act on Principal-to-Principal Basis ITAT Delhi

Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...

March 12, 2026 438 Views 0 comment Print

Interconnect Service Charges Not Royalty: Karnataka HC Dismisses Appeal

Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....

December 10, 2025 549 Views 0 comment Print


Latest Notifications


India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1269 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1797 Views 0 comment Print

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 4563 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 1464 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 933 Views 0 comment Print


Cabinet approves MOC in respect of tax matters with BRICS countries

July 19, 2017 774 Views 0 comment Print

Cabinet approves MOC in respect of tax matters between India and BRICS countries – Brazil, Russia, China and South Africa The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has given the approval for the signing of Memorandum of Cooperation (MOC) in respect of tax matters between India and the Revenue administrations of […]

Complete NRI Guide to Property in India

July 15, 2017 3954 Views 0 comment Print

This article attempts to dispel the doubts in the minds of such prospective NRI investors by addressing key issues pertaining to property dealings in India.

Does constitution of “Service PE” entail physical presence of foreign personnel in host country?

July 7, 2017 4179 Views 0 comment Print

Permanent Establishment (PE) is the fundamental criterion under the tax treaties for taxation of foreign company’s business income in India. A permanent establishment of a foreign company is typically regarded as a virtual extension or taxable presence of such foreign company in the host country, similar to that of an independent legal entity in such country. A PE of a foreign company is required to maintain books of accounts as per the normal accounting principles in the host country, besides undertaking tax compliances alike an independent legal entity.

POEM – Tracking the evolution of new Residency Norm

July 5, 2017 2856 Views 0 comment Print

Place of Effective Management (PoEM) has been one of the most deliberated aspects under the Indian Income Tax regime since its introduction vide Finance Act, 2015, especially for Indian transnational groups.

U S Taxation Vs Canadian Income Tax for individual- a Study

June 29, 2017 1680 Views 0 comment Print

During my recent visit to Southern India, particularly, Tamil Nadu, my family doctor having many covenanted degrees in Medicine from Canada, mentioned about the high income/other tax rates in Canada and also their social commitments to take extra care of the welfare of their citizen.

Draft Notification on foreign company resident in India U/s. 115JH

June 15, 2017 2019 Views 0 comment Print

CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961

Revision of Safe Harbour Rules: A Positive Thought!

June 12, 2017 3654 Views 0 comment Print

In India, new transfer pricing rules were introduced in 2002. Since then, the number of cases identified for audit and the transfer pricing adjustments locked up in disputes have increased tremendously. In order to reduce the increasing number of transfer pricing audits and prolonged disputes

Safe Harbour Rules- Eligible International Transactions

June 9, 2017 4623 Views 1 comment Print

Prabhakar K S  [Ilaya Azwan] The Central Board Of Direct Taxes (CBDT) Vide Notification No. 46/2017 Date 7th June, 2017 Notifies Revised List Of ‘Eligible International Transactions’ For Transfer Pricing Safe Harbour Rules. Sl. No. Eligible International Transactions Circumstances   01 Software Development Services Operating Profit Margin declared by the eligible assessee from the EIT in […]

India Signs MLC to Prevent Base Erosion and Profit Shifting

June 8, 2017 1746 Views 0 comment Print

Finance Minister Shri Arun Jaitley signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting at Paris on 7th June, 2017 on behalf of India.

U S Taxation – Questions Green card holders or U S Citizens wanted to ask from India

June 6, 2017 3621 Views 1 comment Print

1. What are my responsibilities as a green card holder if I have been absent from the United States for a long period of time? 2. I was a long-term resident of the United States prior to surrendering my green card. What is my U.S. tax filing obligation?

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