Income Tax : Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and k...
Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Learn about India's Equalisation Levy, targeting digital transactions like online advertisements by foreign e-commerce firms. Unde...
Income Tax : Explore the impact of BEPS principles and MLI framework on India's Double Taxation Avoidance Agreements (DTAA). Detailed analysis ...
Income Tax : Explore complexities of Business Connection and Permanent Establishment for companies in India. Understand tax implications, signi...
Income Tax : The OECD Committee on Fiscal Affairs has proposed important and far-reaching changes to the Commentary on Article 5 (Permanent Est...
Income Tax : A host of companies from Mumbai, said to be 367 in number and mostly multinational in nature, have moved the recently set up dispu...
Income Tax : A Double Taxation Avoidance Agreement was signed between India and Tajikistan today, i.e. 20th November, 2008. The Agreement was s...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...
Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...
Income Tax : Delhi HC rules Krones' Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority's appeal....
Income Tax : Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when ...
Income Tax : CBDT notifies Section 206C (1G) of Income Tax Act shall not apply to a person (being a buyer) who is a non-resident & who does not...
Income Tax : Public Consultation on the proposal for amendment of Rules for Profit attribution to Permanent (PE) Establishment invited by CBDT....
Bangalore ITAT overturns AO’s PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and interest issues.
Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software revenue, interest income & vendor financing.
Delhi HC rules Samsung India not a ‘Permanent Establishment’ of Samsung Korea. No tax liability under India-Korea DTAA for seconded employees’ roles.
Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.
Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and key judicial interpretations.
Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.
Explore India’s income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal developments.
For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or consultancy services might not fulfill unless such services are directly connected with a PE.
Learn about India’s Equalisation Levy, targeting digital transactions like online advertisements by foreign e-commerce firms. Understand applicability, compliance, and consequences.
Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under India-Thailand DTAA, absence of FTS clause, and PE considerations.
