International Tax

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”

News, Blog, 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”

Blog, News, 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”

News, Blog, 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”

Blog, News, International Tax

January 28, 2022

No denial of nil TDS certificate just because group Co. of assessee involved in tax evasion in similar transaction: HC

Case Details: Celestial Aviation Trading … Continue reading “No denial of nil TDS certificate just because group Co. of assessee involved in tax evasion in similar transaction: HC”

Blog, News, International Tax

January 15, 2022

Switzerland will implement 15% Minimum Tax from 01-01-2024

Swiss Presser, dated 13-01-2022 The … Continue reading “Switzerland will implement 15% Minimum Tax from 01-01-2024”

Blog, Transfer Pricing, International Tax

December 2, 2024

15 Key International Tax and Transfer Pricing Case Laws of the Year 2021

Editorial Team Despite the COVID-19 … Continue reading “15 Key International Tax and Transfer Pricing Case Laws of the Year 2021”

Blog, News, International Tax

December 24, 2021

Canada introduced Digital Service Tax despite commitment to OECD’s Pillar approach

News, dated 23-12-2021 The Canadian … Continue reading “Canada introduced Digital Service Tax despite commitment to OECD’s Pillar approach”