Tag: dtaa
No TDS requirement u/s 195 on employee secondment agreement for payments for reimbursement to a non resident enterprises towards costs of seconded employees. ABCAUS Case Law CitationABCAUS 3432 (2020) (12) HC Important case law relied upon by the parties:M/s Centrica India offshore Pvt. Ltd. vs. Commissioner of income …
Assessee entitled to tax credit u/s 91 of both federal and state taxes paid by him. Benefit also available to not ordinarily resident Indians ABCAUS Case Law CitationABCAUS 3390 (2020) (09) ITAT Important case law relied upon by the parties:Wipro Ltd vs Deputy Commissioner of Income Tax
Mutual Agreement Procedure (MAP) Guidance notes released by CBDT Mutual Agreement Procedure (MAP) The Double Taxation Avoidance Agreements (DTAAs or Tax Treaties) provide rules and mechanisms for allocation of taxing rights amongst the treaty partners; avoidance of economic and juridical double taxation; and resolution of taxation not in …
Project office used as auxiliary office for liaison not a PE unless core business is carried on therefrom – SC ABCAUS Case Law Citation:ABCAUS 3339 (2020) (07) SC Important case law relied upon by the parties:Commissioner of Income Tax and Another v. Hyundai Heavy Industries Co. Ltd., (2007) …
CBDT amends Rule 44G prescribing procedure for making application to give effect to a DTAA to give relief to a resident taxpayer aggrieved by action of foreign tax authority CBDT amends Rule 44G for making application to give effect to a DTAA MINISTRY OF FINANCE(Department of Revenue)(CENTRAL BOARD …
MoU between India and Kuwait in the field of accounting, finance and audit knowledge base approved by Cabinet Cabinet approves MoU between India and Kuwait in the field of accounting, finance and audit knowledge base The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has approved …
Synthesized text of India-Japan income tax treaty as affected by Convention to Implement Measures to Prevent to Prevent Base Erosion & Profit Shifting (MLI) Japan’s Ministry of Finance has released publication of Synthesized Text of Convention to Implement Measures to Prevent to Prevent Base Erosion and Profit Shifting …
Agreement between India and Marshall Islands for exchange of information on tax matters Agreement between the Government of the Republic of India and the Government of the Republic of the Marshall Islands for the exchange of information relating to tax matters. India and Marshall Islands had, on 18th …
India and Brunei sign Agreement for the Exchange of Information and Assistance in Collection with respect to Taxes (TIEA) The Government of Republic of India and the Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam signed an Agreement for the Exchange of Information and …
TDS on payments to non-residents applicable at rates prescribed under DTAAs, not 20 per cent. Section 206AA not override provisions of Section 90(2) – ITAT ABCAUS Case Law Citation: ABCAUS 2615 (2018) (11) ITAT Important Case Laws Cited/relied upon: Azadi Bachao Andolan vs UOI (2003) 263 ITR 706 …
