Income Tax : Delhi HC rules reimbursements to NRAEs not subject to TDS as "fees for technical services," clarifying scope of Section 9(1)(vii) ...
Income Tax : Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications f...
Income Tax : Withholding tax rates for dividends, interest, royalties and Fee for Technical Services in different countries. Understand how tax...
Income Tax : Understand TDS provisions for buyers and sellers in the sale of property in India by an NRI. Get insights into tax rates, implicat...
Income Tax : Learn about Form 15CA and 15CB: Crucial for foreign remittances and tax compliance. A complete guide for taxpayers....
Income Tax : 20% Withholding Tax Rate on profits distributed by unlisted companies to shareholders through buy-back of shares Existing provisio...
Income Tax : Ending year-long battle, UK-based Vodafone has agreed to pay USD 400 million more to its Indian partner Essar for buying its 33 pe...
Income Tax : The government will look into more cross-border mergers involving Indian assets, like the Vodafone-Hutchison deal, after the Bomba...
Income Tax : The Finance (No.2) Act of 2009 introduced section 206AA under the Income Tax Act, 1961 (the ITA) to provide that any person who is...
Income Tax : The cost of doing business in India could come down if the dividend distribution tax (DDT) levied on foreign shareholders is repla...
Income Tax : ITAT Delhi rules that remittances to foreign subsidiaries are not taxable in India, leading to the cancellation of tax penalties o...
Income Tax : Supreme Court dismisses IT Dept's petition, ruling Vodafone Idea isn't liable to deduct TDS on payments to non-resident telecom op...
Income Tax : In a landmark ruling, Delhi High Court quashes TDS penal action against DLF Homes Panchkula Pvt Ltd for the FY 2013-14. Detailed v...
Income Tax : ITAT held that payment made to non-resident without deducting the tax at source u/s. 195 of the Act, does not come under the provi...
Income Tax : Assessee was not having any permanent establishment in India and was providing the service only from Singapore and therefore the p...
Income Tax : CBDT vide notification No. 18/2021-Income Tax, Dated: March 16, 2021 inserted new rule 29BA. Application for grant of certificate ...
Income Tax : For the purpose of making disallowance of other sums chargeable under Section 40(a)(i) of the Income-tax Act, 1961, in the case of...
Income Tax : 37BC. Relaxation from deduction of tax at higher rate under section 206AA.– (1) In the case of a non-resident, not being a compa...
Income Tax : Notification No. 93/2015 - Income Tax G.S.R. 978(E) dated 16th December, 2015 A CA certificate in Form No. 15CB will be required t...
The legal structures adopted by MNEs for tax planning purposes in the traditional businesses are often applied even in the digital businesses. These structures can essentially be broken down into four elements as elaborated in the February 2013 OECD Report on ‘Addressing Base Erosion and Profit Shifting’:
20% Withholding Tax Rate on profits distributed by unlisted companies to shareholders through buy-back of shares Existing provisions of Section 2(22)(e) provide the definition of dividends for the purposes of the Income-tax Act. Section 115- O provides for levy of Dividend Distribution Tax(DDT) on the company at the time when company distributes , declares or […]
What a chartered accountant does exactly is something unknown, which is of course if you’re not an accountant yourself. For many people, an accountant is something that they feel they only need once a year when they are doing their taxes returns. But business and CA are more than just taxes. If you are only using your CA for your tax return you are not using them wisely and missing out on a valuable and informative resource. The truth of the matter is that a chartered accountant is an individual who can help you out in a great many financial areas. Chartered Accountants can deal with a multitude of services and are great source of advice and assistance.
Ending year-long battle, UK-based Vodafone has agreed to pay USD 400 million more to its Indian partner Essar for buying its 33 percent stake in the joint venture Vodafone-Essar. With this, Essar closed the deal to sell its 33 percent stake at USD 5.46 billion as against USD 5 billion decided earlier.
Indian firms outsourcing routine work to their overseas subsidiaries would not have to deduct withholding tax on the payments made to them. In a landmark ruling, the Authority of Advance Ruling (AAR) ( A.A.R. No.883 of 2010 dated 16.05.2010 – Applicant R.R. Donnelley India Outsource Private Limited) held that firms are exempted from deducting the withholding tax on the payments made for services like transcription and data processing.
The decision is relevant to authorised dealers making remittance to non-residents. Though the decision is rendered in the context of remittance to individual’s resident in the UAE, all non-resident Indians can benefit from the principle laid down in
In a recent ruling, the Mumbai Income-tax Appellate Tribunal (the Tribunal), in the case of Wizcraft International Entertainment Pvt. Ltd. (the assessee) held that commission paid by an entertainment event management firm in India to a UK based
On the issue of whether such payments are, alternatively, in the nature of fees for technical services (FTS), liable to tax withholding under any other provision of the ITL, the Mumbai ITAT restored the matter to the Tax Authority for fresh adjudication in the light of the Supreme Court’s (SC) directions in the case of Bharti Cellular Ltd. Hi (Bharti ruling). In this ruling, the SC was concerned with the issue of applicability of withholding tax on interconnection charges paid by one telecom operator to another, on the basis that it constituted FTS. The SC, noting that FTS has been given a restrictive meaning by several High Courts (HC) and ITATs, had referred the matter back to the Tax Authority for fresh adjudication, by taking into account an expert’s opinion on whether any human intervention is actually involved in such transactions.
the assessee-company had made various payments to its holding company M/s. Alstom Holdings, France but no deductions of tax at source were made. – there is justification for the assessee’s conviction at the time of payment that no tax was deductible at source. It was neither a composite payment.
Commission paid to agents for services rendered outside India is not chargeable to tax in India and there is no obligation to deduct tax u/s 195. As Agent was not a performer, his income was not covered under Article 18 of the DTAA but was covered by Article 7 and as the services were rendered outside India and there was no PE, the same was not assessable to tax in India.
