Tax Gyan

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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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.

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)

Saturday International Tax Gyan!! (SITG – 229) #taxmadeeasy #taxinpic Limitation of Relief (LOR) in DTAA and various countries’ DTAA related to Article 8

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

Saturday International Tax Gyan!! (SITG – 227) #taxmadeeasy #taxinpic Provisions of Income Tax Act related to taxation on profit arise from shipping and Air Transport

Saturday International Tax Gyan!! (SITG – 226) #taxmadeeasy #taxinpic Basic Terminologies used in the Article 8 for understanding the taxability on profit from operation of ships or aircrafts

Saturday International Tax Gyan!! (SITG – 225) #taxmadeeasy #taxinpic  Fiscal Transparent Entity can be considered as liable to tax and a tax resident of the country where its owners are paying the tax in the same country on the income of such  fiscal transparent entity.

Saturday International Tax Gyan!! (SITG – 224) #taxmadeeasy #taxinpic Understanding the situation of triangular cases in case of Tax treaties

Saturday International Tax Gyan!! (SITG – 223) #taxmadeeasy #taxinpic TRC benefit and tax exemption under the grandfathering clause cannot be denied under the India- Mauritius DTAA in respect capital gains from ‘indirect transfers’ of shares of Singapore company.