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international taxation

Latest Articles


Tax Avoidance in UK: Key Strategies and Regulations

Income Tax : Explore legal strategies used in tax avoidance in UK, including judicial doctrines, TAARs, GAARs, DOTAS, and the role of HMRC. Lea...

August 13, 2024 324 Views 0 comment Print

UAE Transfer Pricing Compliance Dates

Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....

July 31, 2024 753 Views 0 comment Print

FBAR Submission Guide: U.S. Taxation & Reporting Rules

Income Tax : Understand FBAR requirements for U.S. taxpayers. Learn about reporting foreign financial accounts, penalties for non-compliance, a...

July 21, 2024 534 Views 0 comment Print

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 660 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 840 Views 0 comment Print


Latest News


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 690 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 234 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 70698 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 12336 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 402 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 582 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 309 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 372 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 381 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 507 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 2238 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 867 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 609 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 2403 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 4248 Views 0 comment Print


Form 10F Guide: Tax Treaty Benefits for Non-Resident Receiving Indian Income

January 5, 2024 20862 Views 2 comments Print

Understand Form 10F for non-residents receiving income from India. Learn about electronic filing, recent changes, and the benefits of claiming tax treaty relief with Tax Residency Certificate (TRC).

Decoding Grant Thornton Case: Impact on Cross-Border Transactions

January 4, 2024 1032 Views 0 comment Print

Explore Grant Thornton India LLP case, unraveling complex international tax issues. Analysis of arguments, rulings, and broader implications for businesses in cross-border transactions.

No Profit Attribution if Ricardo India’s Commission Adjusted: Delhi HC

January 2, 2024 459 Views 0 comment Print

Explore Delhi High Court’s ruling in CIT vs Ricardo U.K. Limited. No profit attribution if commission paid to Ricardo India is adjusted against PE profit. Detailed analysis and implications.

Does Establishment of a Business Connection in India Indicate Presence of a Permanent Establishment for a Company?

January 1, 2024 3264 Views 0 comment Print

Explore complexities of Business Connection and Permanent Establishment for companies in India. Understand tax implications, significance, and scenarios.

Recent Developments in International Taxation: Analysis and Implications

December 30, 2023 2841 Views 0 comment Print

Explore the latest in international taxation: from judicial precedents to regulatory changes. Dive into cases, form updates, and MFN clause implications.

What is an Offshore Company: A Comprehensive Guide

December 26, 2023 1515 Views 0 comment Print

It a term that refers to a business entity established in a jurisdiction different from where its beneficial owner resides. At its core, it a company incorporated in a foreign nation, beyond the borders of the owner country. This basic definition, however, barely scratches the surface of what an offshore company truly embodies.

Domain Name Registration Fees Not Royalty: Delhi HC

December 26, 2023 594 Views 0 comment Print

Explore landmark case of Godaddy.Com LLC v. ACIT [2023] and learn why Delhi High Court ruled domain registration fees as not royalty. Get insights on the decision.

Fees for Domain Registration Not Royalty under Section 9(1)(vi): Delhi HC

December 25, 2023 945 Views 0 comment Print

Explore Delhi High Court’s landmark decision on GoDaddy’s domain registration income. Learn why court ruled against treating it as royalty under Section 9(1)(vi) of Income Tax Act.

BEPS 2.0: Unpacking Pillar One and Pillar Two Proposals

December 21, 2023 2424 Views 0 comment Print

Dive into BEPS 2.0 with an in-depth analysis of Pillar One & Pillar Two proposals, reshaping international tax. Explore the impact, India’s stance, and global implications.

No separate notification necessary for application of DTAA’s provisions

December 20, 2023 1341 Views 0 comment Print

Explore the Apollo Tyres Ltd. vs CIT case where issues arise regarding the applicability of DTAA provisions without a new notification.

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