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  • Article

    CBDT Clarifies GAAR Implementation Through 16 Point FAQs

    Inarguably one of the biggest tax reforms that the country has ever witnessed, the General Anti-Avoidance Rules inserted in Chapter X-A of the (Indian) Income-tax Act, 1961 are slated to take effect from 1 April 2017.
    IndiaTax
    Khaitan & Co.
    Khaitan & Co.
  • Article

    Cross-Border Transactions Vis-à-vis Transfer Pricing And Double Taxation

    The intricacies of cross-border transactions could overwhelm, as the process has to be planned from the perspective of transfer pricing and double taxation. Imagine a business group operating with two associated group companies-one each operating Overseas and in India. While the overseas firm searches prospects, finalizes clients, and secures orders, the Indian arm offers software, technical, and operational support. Despite running separate operations, both companies are owned by the same promoters who own and run both businesses. From a business standpoint, this setup works quite well.
    IndiaTax
Foresight Law Offices
Foresight Law Offices
  • Article

    Decoding Tax Fine-Print Finance Bill, 2019

    Vaish Associates Budget 2019 presentation.
    IndiaTax
    Vaish Associates Advocates
    Vaish Associates Advocates
  • Article

    Delhi High Court Holds That No Disallowance Under Section 40(a)(i) Of The Income-Tax Act, 1961, For Failure To Deduct Tax From Payments Made To US Company, Was Called For In View Of Non-Discrimination Provisions Under The Treaty

    The assessee, an Indian company and a subsidiary of Herbalife of International America Inc., a company incorporated in USA, was engaged in the business of manufacturing herbal products used in weight management, for improving nutrition and enhancing personal care.
    IndiaTax
    Vaish Associates Advocates
    Vaish Associates Advocates
  • Article

    Dividend Distribution Tax – Whose Tax Is It Anyway? – Recent Developments On Issue Before Bombay High Court And Supreme Court Of India

    Section 115-O of the Income-tax Act, 1961 (‘IT Act 1961’) states that in addition to the tax payable on the income earned in the hands of a domestic company, an additional income-tax shall be levied upon such company...
    IndiaTax
    AZB & Partners
    AZB & Partners
  • Article

    India Budget Analysis 2018-19

    Earlier today, the Indian Finance Minister ("FM") announced the Budget for financial year ("FY") 2018-19 ("Budget").
    IndiaTax
    Nishith Desai Associates
    Nishith Desai Associates
  • Article

    India Withdraws The Infamous Retrospective Amendment

    The Government of India has finally passed a bill to withdraw the retrospective nature of the Indirect Transfer tax amendment. This retrospective amendment to the Income Tax Act was...
    IndiaTax
    Nexdigm Private Limited
    Nexdigm Private Limited
  • Article

    Supreme Court Rules That Liaison Office Does Not Constitute A Taxable Presence In India

    The Supreme Court of India in Union of India & Anr v UAE Exchange Centre, held that the liaison office set up by UAE Exchange Centre LLC in India does not constitute its permanent establishment in India.
    IndiaTax
    Khaitan & Co.
    Khaitan & Co.
  • Article

    Tax Street - April 2021

    We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month...
    IndiaTax
    Nexdigm Private Limited
    Nexdigm Private Limited
  • Article

    Taxation Of Overseas Investments By Indian Investors Decoded

    Overview of the Indian tax aspects and costs to be borne in mind when planning offshore investments by Indian resident individuals.
    IndiaTax
    JSA Advocates & Solicitors
    JSA Advocates & Solicitors
  • Article

    Apex Court Provides Relief To The Outsourcing Sector On The Issue Of Permanent Establishment

    The Supreme Court held that rendition of support services by Indian group company to its parent company in the US would not lead to creation of permanent establishment (PE) of the parent company in India in terms of India-USA Double Taxation Avoidance Agreement (DTAA).
    IndiaTax
    Khaitan & Co.
    Khaitan & Co.
  • Article

    India Signs A Tax Treaty With Hong Kong

    Hong Kong is a significant economic partner of India in terms of trade and investment. India is Hong Kong's seventh largest trading partner and the total value of bilateral trade has reached HKD 266 billion.
    IndiaTax
    Nexdigm Private Limited
    Nexdigm Private Limited
  • Article

    Pitfall Of Double Tax Avoidance Agreement Between India And Mauritus Due To AAR

    The Authority of Advanced Ruling (AAR), New Delhi dismissed the petition in the case of Tiger Global International II Holdings, Mauritius & Ors (Petitioner),
    IndiaTax
    King, Stubb & Kasiva
    King, Stubb & Kasiva
  • Article

    Base Erosion And Profit Shifting (BEPS) The Biggest International Tax Reform In The Past Century?

    In the last few years, media reports revealed that the effective tax rates of some leading Multinational Corporations (MNCs) are lower than 1% of their revenues.
    IndiaTax
    Nexdigm Private Limited
    Nexdigm Private Limited
  • Article

    GAAR And New Developments

    Nowadays GAAR has become one of the most discussed and talked about topic in Indian Tax Environment. GAAR or General Anti- Avoidance Rules are expected to have long term and widespread effect.
    IndiaTax
    S&A Law Offices
    S&A Law Offices
  • Article

    High Court Allows Import Of UK Treaty Into France Treaty: Invokes Mfn Clause

    Protocols under a treaty form a part of it and do not need to be notified separately unless the treaty/protocol itself suggests otherwise.
    IndiaTax
    Nishith Desai Associates
    Nishith Desai Associates
  • Article

    India Withdraws Dividend Distribution Tax

    In a bold move aimed at increasing foreign investment, India has announced the withdrawal of its dividend distribution tax
    IndiaTax
    Mayer Brown
    Mayer Brown
  • Article

    ITAT Delhi Examines Principal Purpose Test And Allows The Benefit Under India-Luxembourg Tax Treaty

    In a first of its kind ruling, the Delhi bench of the Income Tax Appellate Tribunal (ITAT) in the case of SC Lowy P.I. (LUX) S.A.R.L. vs. ACIT, (ITA No.3568/DEL/2023) has adjudicated on the merits of the PPT provisions ...
    IndiaTax
    Khaitan & Co.
    Khaitan & Co.
  • Article

    ITAT Ruling In The Case Of SC Lowy

    This is the first case in India where the Tribunal had decided on the entitlement of treaty benefit to the taxpayer, post implementation of principal purpose test.
    IndiaTax
    Vaish Associates Advocates
    Vaish Associates Advocates
  • Article

    Notional Interest To Be Subjected To Indian Transfer Pricing Provisions? Special Bench Asks Tribunal To Decide

    The ITAT made an observation that the judicial precedent relied upon by the taxpayer does not discuss the connotations of the expression ‘paid,' especially in the context of Article 3(2) of the Treaty read with Section 43(2) of the Indian Income-tax act.
    IndiaTax
    Nexdigm Private Limited
    Nexdigm Private Limited
  • Showing 101–120 of 319 results

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