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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...
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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...
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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....
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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...
Aggregation of transactions or ‘Combined Transaction Approach’ is a well-accepted practice for benchmarking and determination of Arms’ Length Price of international transaction/ specified domestic transactions in Transfer Pricing Certification and assessments and is widely upheld in many judgements.
The treatment of extended credit period to Associated Enterprises(AEs) as an international transaction and making adjustment of notional interest on the same has always been bone of contention between the assessee and department.
CBDT has, vide Notification no. 54/2016 dated 27th June 2016, notified Rules for grant of Foreign Tax Credit (FTC). The said rules are applicable from Assessment Year 2017-18 onwards. Earlier, the CBDT had released draft FTC rules on 18th April 2016 for public comments and on the basis of comments received, the final rules are notified.
The Protocol provides for source-based taxation of capital gains arising from alienation of shares acquired on or after 1st April, 2017 in a company resident in India with effect from financial year 2017-18.
The Union cabinet on Wednesday approved the revised double taxation avoidance agreement (DTAA) with Cyprus which will help close gaps and enable Indian authorities to tax capital gains in the country for investments originating in the Mediterranean island nation.
Assessee submitted that project receipt from Tanakpur Power Project of NHPC work is exempt from tax in India for the reason that assessee does not have continuous presence or ‘business connection’ or a permanent establishment in India.
Recently Government of India has notified the revised tax treaty with Mauritius which was signed by both countries on 10 May 2016 under which India will impose capital gains tax on investments routed through the island nation from 1 April 2017 to curb tax evasion.
The Tax filing season in the US usually starts on the 31st of January each year and ends on 15th April. In the following sections we shall discuss how income generated in India is taxed for the NRIs’ in U.S. This rule holds for all who are foreign nationals, meaning those who are a citizen of a country other than the U.S. but relocates to U.S. and earns income from there. For those who are U.S. resident or citizen, taxes have to be paid on the global income in the U.S.
An individual is usually accustomed to the tax rates and tax structure of his/her home country. Tax rates are different in different countries. If an employee is deputed from his home country to another country certainly his net income will be impacted because of difference in tax rates. e. g. If an Indian employee (effective tax rate is about 25%) is deputed to Saudi Arabia (zero tax) he will be very happy because his net take home will increase by 25%. But the same employee will be unhappy if he is deputed to some of the European countries where tax rates are very high. The concept of tax equalization came up so that the employee is “neither better off nor worse off” because of deputation to another country.
Foreign Tax Credit.- (1) An assessee, being a resident shall be allowed a credit for the amount of any foreign tax paid by him in a country or specified territory outside India, by way of deduction or otherwise, in the year in which the income corresponding to such tax has been offered to tax or assessed to tax in India, in the manner and to the extent as specified in this rule
