Income Tax - There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]...
Read MoreIncome Tax - With the incessant global growth, the relevance of Permanent Establishment (PE) in international taxation has become paramount. In simpler terms, the expression ‘Permanent Establishment’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on....
Read MoreIncome Tax - In this dynamic era, the brick and mortar business models are turning digital and Multi-National Companies (MNCs) are effectively operating out of various jurisdictions without having a physical presence. From a taxation perspective, it is way more challenging when the value creation, income generation and the adjoining taxability cut acr...
Read MoreIncome Tax - The global tax landscape is constantly evolving to keep pace with ever-changing business models and structures. Introduction of the Base Erosion and Profit Shifting (BEPS) project by OECD/G-20 in the year 2016 was one such significant international stepsince the advent of bilateral tax treaties, wherein more than 100 countries collaborate...
Read MoreIncome Tax - INTRODUCTION: > Any country suffering disputes with respect to Transfer Pricing adjustments, Existence of a Permanent Establishment, Attribution of profits to a Permanent Establishment, Characterisation or re-characterisation of an income or expense lead, on being result taken, by legal or administrative authorities as per domestic law...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of th...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND ...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN ...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNME...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Austria tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE CONVENTION BETWEEN THE G...
Read MoreABB FZ - LLC, Bangalore Vs. Dy.DIT, Bangalore (ITAT Bangalore) - A reader should be able to come to his / her own conclusion by applying the legislative enactments and judicial pronouncements to the facts of the case. While re-producing any portion of legislative enactment or judicial pronouncement, it is para phrased and emphasis is supplied by way of underline....
Read MorePoonam Jain Vs Union of India & Ors. (Delhi High Court) - High Court held that to say that the person being prosecuted or proceeded against can only be 'shown' such documents, but not provided copies thereof is untenable even on a plain reading of Article 26 (2) of the OECD Model Convention....
Read MorePR No. 297/2015 - (23/12/2015) - PR No. 297/2015 Sixth Meeting of the International Advisory Board of SEBI The Sixth meeting of the International Advisory Board (IAB) of the Securities and Exchange Board of India (SEBI) was held on December 21 & 22, 2015. The following major issues were inter alia discussed during the meeting: ...
Read MoreF. No. 500/137/2011-FTTR-III - (31/08/2015) - To combat the problem of offshore tax evasion and avoidance and stashing of unaccounted money abroad requiring cooperation amongst tax authorities, the G20 and OECD countries working together developed a Common Reporting Standard (CRS) on Automatic Exchange of Information (AEOI). The CRS on AEOI was...
Read More