Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
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...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
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 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 Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
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...
Greece has signed the Convention on Mutual Administrative Assistance in Tax Matters, a multilateral agreement that was developed jointly by the Council of Europe and the OECD and that is open for signature to all countries. The Convention promotes international co-operation in the assessment and collection of taxes.
195. [(1)Any person responsible for paying to a non-resident, not being a company, or to a foreign company, any interest or any other sum chargeable under the provisions of this Act (not being income chargeable under the head “Salaries” shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier, deduct income-tax thereon at the rates in force :
The Income Tax department today said there is no great ambiguity in international tax laws and the Government wants to have more transparency in deals. There are issues…debatable issues, but there is no great ambiguity in international tax laws, Director General of Income Tax, International Taxation, R N Dash, said on the sidelines of a CII event here.
CBDT Vide Order No. 81 of 2011 dated 9.5.2011, the CBDT has transferred & posted Additional/ Joint CITs in the Directorate of International Taxation & Transfer Pricing. Vide Order No. 82 of 2011 dated 9.5.2011, the CBDT has transferred & posted Deputy/ Assistant CITs.
We are pleased to announce that the Committee on International Taxation of ICAI has decided to commence the next Batch of the Certificate Course on International Taxation in Hyderabad from Saturday 21st May, 2011.
The government is likely to plug loopholes in international taxation to swell its kitty, since it does not have too many options to raise taxes in the upcoming Budget due to proposed rates in new direct and indirect tax regimes and high inflation. R
The arena of International taxation has always been quite complex as much as it has been exciting (for tax practitioners in particular). What with residency rules, PE provisions, TP regimes, 195 issues and DTAAs, in fact, it will be more exciting as
Income shall be deemed to accrue in India if it accrues, directly or indirectly through or from transfer of a capital asset situated in India. However, the income from the transfer by a non?resident of any share or interest in a foreign company would not be considered as income, wherein at any time in twelve months preceding the transfer, the fair market value of the assets in India, owned, directly or indirectly, by the company, represent at least fifty per cent of the fair market value of all assets owned by the company.
A computer software when put into a media and sold, it becomes goods like any other audio cassette or painting on canvass or book. The amount paid by the assessee towards purchase of IXOS-eCON for R/3 50 users cannot be treated as payment of royalty taxable in India under Article 12 of DTAA between India and Singapore. Therefore, the assessee, in our opinion, is not liable to deduct tax at source.
Direct Taxes, now the major resource provider to the Central Government, have grown at an average annual rate of 24 percent in the last five years and have nearly trebled from Rs.1,32,771 crore in financial year 2004-05 to about Rs.3,78,000 crore in financial year 2009-10, increasing its share from 4.1 percent to 6.1 percent of the Gross Domestic Product (GDP).
