Diamond Dollar Account (DDA)
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Diamond Dollar Account” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
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Non-exclusive distribution rights will not be considered as Royalty
Saturday International Tax Gyan!! (SITG – 232) #taxmadeeasy #taxinpic Distribution of television channels will not give rise to transfer of copyright in favour of Indian entities, payments made by Indian entities to assessee would not fall within ambit of consideration for use of, or right to use, any copyright of literary, artistic or scientific work …
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Dear all,
This time we have come up with an interesting FEMA Provisions relating to “Custom Baggage” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Tie Breaker Rule – Stay of immediate nuclear family is important
Saturday International Tax Gyan!! (SITG – 231) #taxmadeeasy #taxinpic While testing tie breaker rule, the economic interest will be where assessee is involved in day to day working and also where his immediate nuclear family stays.
Dear all,
This time we have come up with an interesting FEMA Provisions relating to “Overseas Investment by Person Resident in India other than Indian Entity and Resident Individual” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Shareholding of ultimate holding to be seen in Indirect transfer
Saturday International Tax Gyan!! (SITG – 230) #taxmadeeasy #taxinpic In case of Indirect transfer of shares taxability in India is to be seen based on holding of the ultimate company selling shares in the share capital of Indian company. India Opportunity Fund I F.C.R vs DCIT-2(2)(1), Mumbai. I.T.A. No. 4536/Mum/2023 (Mumbai Tribunal)
Resident Foreign Currency (Domestic) Account
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Residential Foreign Currency domestic Account” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Part 4 of Series on Article 8 – Profit arise from shipping and Air Transport
Saturday International Tax Gyan!! (SITG – 229) #taxmadeeasy #taxinpic Limitation of Relief (LOR) in DTAA and various countries’ DTAA related to Article 8
Issue of ESOP’s by Indian Entity to a PROI
Dear all,This time we have come up with an interesting FEMA Provisions relating to “Issue of Esop by an Indian entity to a PROI” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Part 3 of Series on Article 8 – Profit arise from shipping and Air Transport
Saturday International Tax Gyan!! (SITG – 228) #taxmadeeasy #taxinpic Understanding Article 8 of OECD and UN Model conventions for the taxability on profit from operation of ships or aircrafts