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...
President Trump’s “Tax Reform 2025” bill introduces extensive changes to US individual and business tax laws, affecting deductions, credits, and exemptions.
Explore why foreign exchange gains/losses, particularly on revenue items, should be excluded from Profit Level Indicator (PLI) calculations in Transfer Pricing, challenging current judicial precedence and OECD guidelines.
AO treated this amount as fees for technical services (FTS) taxable in India, and Dispute Resolution Panel (DRP) upheld the assessment. DRP looked into whether the payment made by an Indian company, FSTI, to Ethiopian Airlines (EA) was taxable in India as FTS.
ITAT Delhi remands Orange Business Services India’s transfer pricing case, ordering separate benchmarking for IT and ITES segments based on consistency and directing the use of the headcount method for expense allocation.
Learn when NRIs must file income tax returns, applicable TDS provisions, residential status rules, and taxability of various incomes in India. The FAQs also explain FEMA provisions and important tax exemptions available to non-residents.
ITAT Ahmedabad clarifies corporate guarantees as international transactions, yet upholds Adani Ports’ appeal on no arm’s length adjustment, citing no AE benefit.
In today’s interconnected world, global trade and cross-border investments are the backbone of economic growth. No nation remains entirely self-reliant—countries rely on imports, exports, and foreign capital to drive their economies. However, this interdependence has led to complex tax issues, particularly double taxation, where the same income is taxed in more than one country. To […]
Delhi High Court upholds ITAT ruling: Cloud service subscription payments to foreign firms are not taxable as royalty under DTAA or Income Tax Act.
Delhi High Court dismisses appeals, reiterating Supreme Court ruling that payments for software use/resale are not royalties under Indian tax law. No TDS liability.
The Delhi High Court ruled that subscription fees for Salesforce CRM software are not royalty income under the India-Singapore DTAA or the Income Tax Act, citing prior judicial precedents.
