International Tax

Blog, News, International Tax

May 26, 2022

Agreement can’t be said as not for ‘tax avoidance’ mere because ultimately no tax was avoided: UK Tribunal

Case Details: Tower One St … Continue reading “Agreement can’t be said as not for ‘tax avoidance’ mere because ultimately no tax was avoided: UK Tribunal”

Blog, News, International Tax

May 20, 2022

AO can’t import ‘beneficial ownership’ under Article 13 of Indo Mauritius DTAA: ITAT

Case Details: Blackstone FP Capital … Continue reading “AO can’t import ‘beneficial ownership’ under Article 13 of Indo Mauritius DTAA: ITAT”

Blog, International Tax

July 18, 2024

Taxation of Expatriate Employees | Secondment | Cross Border Movement

Table of Contents Introduction What … Continue reading “Taxation of Expatriate Employees | Secondment | Cross Border Movement”

Blog, News, International Tax

March 28, 2022

Business support service is tax exempt applying MFN clause under India-Belgium tax treaty

Shailendra Sharma – [2022] 136 … Continue reading “Business support service is tax exempt applying MFN clause under India-Belgium tax treaty”

Blog, News, International Tax

March 10, 2022

Claim of FTC can’t be disallowed just because Form no. 67 wasn’t filed by due date: ITAT

Case Details: Ms. Brinda RamaKrishna … Continue reading “Claim of FTC can’t be disallowed just because Form no. 67 wasn’t filed by due date: ITAT”

Blog, News, International Tax

March 5, 2022

Sec. 44BB applies to charter hire charges received by NR for transporting equipment from yard to offshore sites: HC

Case Details: Larsen & Toubro … Continue reading “Sec. 44BB applies to charter hire charges received by NR for transporting equipment from yard to offshore sites: HC”

News, Blog, International Tax

February 26, 2022

Term ‘Process’ defined by section 9 can’t be imported to interpret ‘secret formula or process’ used in DTAA: ITAT

Case Details: ACIT v. Viacom … Continue reading “Term ‘Process’ defined by section 9 can’t be imported to interpret ‘secret formula or process’ used in DTAA: ITAT”

Blog, News, International Tax

February 25, 2022

‘Make Available’ clause is not satisfied if NR services are repetitive in nature

Case Details: GE Energy Management … Continue reading “‘Make Available’ clause is not satisfied if NR services are repetitive in nature”

Blog, News, International Tax

February 15, 2022

Sum recovered from Indian affiliate for software used to provide services to various group entities is royalty: ITAT

Case Details: Rieter Machine Works … Continue reading “Sum recovered from Indian affiliate for software used to provide services to various group entities is royalty: ITAT”

Blog, News, International Tax

February 9, 2022

No PE exists if ESPN India rendering support services to enable NR to render services to their clients abroad: ITAT

Case Details: ESPN Star Sports … Continue reading “No PE exists if ESPN India rendering support services to enable NR to render services to their clients abroad: ITAT”