ODI by way of Swap of Securities
Dear all, This time we have come up with an interesting FEMA Provisions relating to “ODI by way of Swap of Securities”#FEMAkeFUNDAE #FamiliarwithFEMA #rbi
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February 2025
Taxability under Residual article of DTAA
Saturday International Tax Gyan!! (SITG No. 246) #taxmadeeasy #taxinpic Part- 6 of a new series “Back to Basic Principles” wherein we shall discuss some basic principles of DTAA read with Income tax act. If any income is not taxable in any particular article of Tax Treaty, whether the same would be taxable in residuary article …
Global Depository Receipt
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Global Depository Receipt”FEMAkeFUNDAE#FamiliarwithFEMA#rbi
Retrospective amendment in the act cannot be read into DTAA
Saturday International Tax Gyan!! (SITG No. 245) #taxmadeeasy #taxinpic Part- 5 of a new series “Back to Basic Principles” wherein we shall discuss some basic principles of DTAA read with Income tax act. Retrospective amendments cannot be implemented unilaterally
Direct dispatch of shipping documents by the exporter
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Direct dispatch of shipping documents by the exporter”#FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Treaty to be read as a whole and not in isolation
Saturday International Tax Gyan!! (SITG No. 244) #taxmadeeasy #taxinpic Part- 4 of a new series “Back to Basic Principles” wherein we shall discuss some basic principles of DTAA read with Income tax act. Treaty must be read in their entirety, considering their context and purpose. It should not be like that only beneficial fact should …
Treaty to be read as a whole and not in isolation Read More »
Cross Border Outbound Merger Part 2of 2
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Cross Border outbound Merger part2”#FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Guidance on the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements (DTAAs)
Saturday International Tax Gyan!! (SITG No. 243) #taxmadeeasy #taxinpic The PPT is a general anti-avoidance rule applied under DTAAs. PPT in India’s tax treaties states: ‘If it is reasonable to conclude that one of the principal purposes of a transaction or arrangement is to obtain a tax benefit, the tax benefit can be denied, unless …