Tiger Global International II, III and IV Holdings, Mauritius
Benefit of India-Mauritius treaty won’t be available as after the lifting corporate veil it was seen that POEM was in USA and not Mauritius.
Menu
Tax Gyan
Volkswagen Finance Pvt Ltd v. Income Tax Officer
Payment to Non-residents for events outside India to promote the business of the Company in India was liable to TDS in India.
Significant Economic Presence
Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Understanding and discussing the concepts of significant economic presence introduced by Income tax department in Income tax act and it’s impact on business transaction done with India.
Payment to Non-resident for use of Software, Not taxable as Royalty – Supreme court
Supreme court has put the discussion to rest by passing a judgement that payment made to non-resident for getting a right to use the software is not taxable as royalty – Engineering Analysis Centre Of Excellence Pvt Ltd vs. CIT [125 taxmann.com 42 (SC)]
Corporate veil lifted to check applicability of DTAA benefit
In this post we shall discuss about court’s lifting corporate veil to check on the applicability of benefit under various DTAA. The judgement was pronounced in an AAR ruling in case of Tiger Global International II, III and IV Holdings, Mauritius [2020] 116 taxmann.com 878 (AAR – New Delhi)
Understanding the basics of International Taxation – Landmark Supreme court Judgement
In this article we shall discuss about the landmark Supreme Court judgement pronounced in case of Union of India v. Azadi bachao Andolan which is the base of any discussion about International Taxation. Union of India v. Azadi Bachao Andolan [2003] 132 Taxman 373 (SC)
How to claim Foreign Tax credit in India – Form 67 – JSCO | SITG
Saturday International Tax Gyan!! #taxmadeeasy #taxinpic In this article we shall understand how a resident Indian can claim credit of tax paid in foreign country using Form 67 and what to feed in Form 67 while claiming foreign tax credit.