Double taxation

India – Latvia sign DTAA

An Agreement and Agreed Note Signed Between India and Latvia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (DTAA) The Government of India today signed an Agreement and the Agreed Note for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect… Read More

Tags: Baltic statesDouble taxationDTAAExternal Affairs MinisterGovernment of IndiaIncome taxIndiaLatvia

DTAA with Albania

Agreement Signed between the Republic of India and the Republic of Albania for the avoidance of double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital The Government of India signed here today an Agreement for Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect… Read More

Tags: AlbaniaDouble taxationDTAAGovernment of IndiaIncome taxIndiaTax treatyTaxation in India

ITAT Special Bench Explains Important Law On Force Of Attraction

CLR Editorial Notes: The assessee, in this particular case is a U.K. partnership firm of Solicitors, which provides legal consultancy services in connection with different projects in India. The assessee claimed in its assessment, that the taxability of the income had to be processed under Article 15 (independent professional services) which forms part of the… Read More

Tags: Bombay High CourtClifford ChanceDouble taxationHigh CourtIndiaLinklaterMumbaiSupreme Court

ITAT Explains Important Law On Attribution Of Profits To PE

CLR Editorial Notes: In this case related to Profit attribution to PE, the Tribunal had to consider the following legal issues: (i) whether the assessee could be said to have a PE in terms of Article 5(1) and 5(2) of the DTAA? (ii) what is the correct method to allocate profits to the PE?, (iii) whether fees… Read More

Tags: BusinessCommonwealth Law ReportsDouble taxationFinance ActIndiaProfit (economics)Royaltiestransfer pricing

Foreign company is liable for MAT u/s 115JB

CLR Editorial Notes: The applicant, a Mauritius company, sold shares of Burroughs Wellcome (India) Ltd. The resultant capital gains were not chargeable to tax under the India-Mauritius DTAA. The AAR had to consider whether, as the Applicant had no income chargeable to tax in India, (a) the transfer pricing provisions were applicable to its, (b) section 115JB (MAT) was… Read More

Tags: AARCompanies ActDana CorporationDouble taxationIndiaMauritiusSupreme CourtTimken Companytransfer pricingUnited States

Income Tax Overseas Units

Income Tax Overseas Units have been set up in Indian Missions abroad as part of efforts to unearth black money. Tax Officers at the level of First Secretary are being posted to Income-tax Overseas Units (ITOUs) in Indian Missions abroad to maintain effective coordination and liaison between Indian tax authorities and the tax authorities of… Read More

Tags: CyprusDouble taxationExchange of InformationIncome taxMauritiusMinistry of External AffairsSingaporeUnited States

DTAA protocol signed between India and Malta

An Agreement (DTAA) and Protocol Signed Between India and Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income The Double Taxation Avoidance Agreement (DTAA) and the Protocol between the Republic of India and Malta for the avoidance of double taxation and for the prevention of fiscal… Read More

Tags: Double taxationDTAAForeign ministerGeorge William VellaIndiaMaltaPreneet KaurTax treaty

GoI negotiating new Double Taxation Avoidance Agreements with Sweden

Government of India is negotiating new Double Taxation Avoidance Agreements (DTAAs) and has also taken steps to update the article concerning Exchange of Information in existing DTAAs to specifically allow for exchange of banking information and information without domestic interest. India has also decided to negotiate Tax Information Exchange Agreements (TIEAs) with priority countries/jurisdictions. On… Read More

Tags: Amending ProtocolDouble taxationDTAADTAA with SwedenDTACTax Information Exchange Agreements

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