Double Taxation and Connecting Factors
Double Taxation and Connecting Factors Taxability of a foreign entity /taxpayer, in any country depends upon the : – a) Residence of Taxpayer – Generally,
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Double Taxation and Connecting Factors Taxability of a foreign entity /taxpayer, in any country depends upon the : – a) Residence of Taxpayer – Generally,
What is International Tax Law? International tax law are the tax laws, which apply to tax income from activities, that takes place in two or more
MEASURES FOR ANTI – TREATY SHOPPING IN TAX TREATIES BENEFICIAL OWNERSHIP The concept of “beneficial owner” implies, that the concessional withholding tax benefit, under a
BEPS ACTION PLANS OECD BEPS Action Plan has sets forth 15 Action Plans, which are designed to address BEPS, by bringing fundamental changes to the
WITHHOLDING TAX FROM PAYMENTS TO NON-RESIDENTS SALARY PAYABLE IN FOREIGN CURRENCY – SECTION 192 In terms of Rule 26 read with Rule 115, where tax
Income deemed to accrue or arise in India – Section 9 of Income Tax Act ACTIVITIES CONFINED TO DISPLAY OF ROUGH DIAMONDS IN SNZS [EXPLANATION
FEES FOR TECHNICAL SERVICES – SECTION 9(1)(vii) OF INCOME TAX ACT – SUMMARY OF KEY PROVISIONS AND TAXABILITY FTS payable to the non- resident ,
DEEMED ACCRUAL/ARISING OF ROYALTY INCOME – SECTION 9(1)(vi) OF INCOME TAX ACT Royalty payable to the non- resident , could be from the following payors
DEEMED INTEREST INCOME – SECTION 9(1)(v) OF INCOME TAX ACT Interest payable to the non- resident , could be from the following Payors : –
WHAT ARE OFFSHORE FUNDS Offshore funds are mutual fund schemes, which invest in equities of a region or country, or fixed income securities in international
EXEMPT INCOME OF NON-RESIDENTS – The tax exemptions available to various incomes of a non-resident under Section 10 of the Income Tax Act are discussed
Presumptive Taxation for Non residents – Introduction In certain cases, it is difficult for the non-resident to maintain India specific books of accounts, given the