Royalty vs. Fee for technical services vs. Business Profit As per International tax rules for Non-Resident Taxation, specific income of Non-residents have been excluded from the business Income so as to give taxing rights to the source Countries in respect …
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read moreCommission to Overseas Agent- Is Fee for Technical Services? Commission earned by Non-resident overseas agent from an Indian Company- Whether Taxable in India? Firstly, Taxability of any income in the hands of non-resident is be determined as per the provision …
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read moreInternational collaboration to end tax avoidance Gone are the days? When a MNE incorporated in a Country, while its POEM is in a tax heaven, its production is in another jurisdiction and customers are located in some other jurisdiction, can …
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read moreRole of International Financial Services Centres’s (IFSC) in India’s Growth Story – An Unfinished Agenda It is estimated that Indian households have accumulated considerable wealth outside the country; well beyond the present limits set by RBI. The ability of Indian …
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read moreTransfer Pricing – Practical Issues Series – 1/2021 Transfer pricing is one of the most litigated areas of International Tax around the World. There are so many controversies since the inception of the TP provisions in India in 2002. In …
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read moreIntroduction and Importance of Transfer Pricing in India Setting Context: Transfer pricing in India plays a pivotal role in the case of cross border transactions between related parties in determining on pricing arrangement of supply of goods or services between …
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read moreFEMA non – compliance may lead to huge loss under GST and unrepairable loss of repute to include in Caution List of Exporters Setting Context Export of goods and services from India is governed by Section-7(1)(a) & (3) of FEMA …
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read moreSuspicious – Liberalised Remittance Scheme Interplay with Black Money Act and Income Tax Act Setting Context: Foreign Exchange Management Act (FEMA) is the regulation which take care of all Foreign Exchange dealing of Residents in India. The Act is applicable …
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read moreStringent Provisions under Black Money Act Setting Context: The Black Money (Undisclosed foreign Income and Assets) and imposition of Tax Act 2015 (BMA) was born after the Apex Court expressing concern over the issue of Black Money and recognising …
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read moreLower Deduction or No deduction of Tax on Payments to Non-residents Setting Context Non-resident is at disadvantage when he sells his properties in India as compared to residents as they are subject to deduction of income tax at the rate …
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