Income Tax : Family disputes and consequential family partition and family arrangements are not new in Indian history. Since ages, the human ci...
Income Tax : There is a never ending debate on whether software related payment made by a resident to a foreign recipient is in the nature of R...
Income Tax : Whether or not the royalty/fees for technical services is taxable in India in the hands of the non-resident, will depend on provis...
Income Tax : The term ‘demerger’ simply means one company transferring one or more of its business operations into another company(s). The ...
Income Tax : The concept of Permanent Establishment is one of the most important concepts in International Taxation. The existence of a Permane...
Family disputes and consequential family partition and family arrangements are not new in Indian history. Since ages, the human civilization has been exposed to disputes, settlement and arrangements within the family.
There is a never ending debate on whether software related payment made by a resident to a foreign recipient is in the nature of Royalties or Fees for Technical Services or Business Income.
Whether or not the royalty/fees for technical services is taxable in India in the hands of the non-resident, will depend on provisions of Income Tax Act, 1961 (‘Act’) and the relevant Double Taxation Avoidance Agreement, if any. Further whether such royalty/ fees for technical services will also be taxed in the home country of the recipient will depend upon the provisions of the tax laws of such home country.
The term ‘demerger’ simply means one company transferring one or more of its business operations into another company(s). The company that transfers such business operation is known as the “demerged” company, while the company to which the business is transferred is known as the “resulting” company. Demerger is an opposite of merger a statutory disintegration or separation of two or more companies by the transfer of the properties to one surviving company.
The concept of Permanent Establishment is one of the most important concepts in International Taxation. The existence of a Permanent Establishment or otherwise, would in most cases determine the exposure to domestic tax liability in the country of source.
Intellectual property rights (IPR) have become important in the face of changing trade environment which is characterized by the following features namely global competition, high innovation risks, short product cycle, need for rapid changes in technology, high investments in research and development (R&D), production and marketing and need for highly skilled human resources. Geographical barriers to trade among nations are collapsing due to globalisation, a system of multilateral trade and a new emerging economic order. It is therefore quite obvious that the complexities of global trade would be on the i
Dividend stripping refers to transacting in shares or securities linked to shares of a company on which dividend is payable. Typically, a dividend stripping transaction can be explained with an illustration.
A rights issue is basically when a company offers existing shareholders a right to purchase additional shares of the company at a given price, which is at a discount to the prevailing market price of the stock, to make the offer enticing for the shareholder and to ensure that the rights offer is fully subscribed to.
IASs have no explicit concept of functional currency. Whatever currency the accounts are presented in is simply known as the reporting currency (all other currencies are foreign currencies) and its role in the translation processes is similar to that of the US and UK functional currency.
It is commonly known that levy of excise duty arises on manufacture and the duty is collected on removal of goods from the factory. However, all manufacturing process does not attract levy of excise duty unless some basic conditions are met.
