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Category: International Tax

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Capital gain on sale of property situated in Sri Lanka is taxable only in Sri Lanka

tenet-tax-daily-august-15-2016

Posted onon November 4, 2016
  • Corporate Tax
  • International Tax

The transaction couldn’t be deemed as international transaction due to its inadvertently disclosure in Form 3CEB

tenet-tax-daily-august-09-2016

Posted onon November 4, 2016
  • Corporate Tax
  • International Tax

Retro-amendment to the definition of ‘royalty’ can’t be imported into Articles of treaty

Tenet Tax Daily August 08 2016

Posted onon August 8, 2016
  • Corporate Tax
  • International Tax

Mere use of technology won’t make any service as ‘FTS’ u/s 194J

Tenet Tax Daily July 28 2016

Posted onon August 6, 2016
  • Corporate Tax
  • International Tax

Sum paid to facilitate Call Centers to communicate with USA customers held as ‘royalty’

Tenet Tax Daily July 23 2016

Posted onon August 6, 2016
  • Corporate Tax
  • International Tax

Fee paid by stock broker for marketing services couldn’t be held as FTS under India-UK treaty

Tenet Tax Daily July 22 2016

Posted onon August 1, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

Salary earned in USA exempted from tax as employee was held as resident of USA under tie-breaker rule of DTAA

Tenet Tax Daily July 13 2016

Posted onon July 19, 2016
  • Corporate Tax
  • International Tax

Duration of running each project undertaken by a Mauritian Co. to be seen separately for determination of PE in India

Tenet Tax Daily July 12 2016

Posted onon July 19, 2016
  • International Tax

Payment for bio-analytical services provided by foreign Cos couldn’t be held as ‘FTS’ under India-USA treaty

Tenet Tax Daily July 06 2016

Posted onon July 18, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

ITAT taxes salary received in India; dismisses employee’s claim of having received salary on high seas

Tenet Tax Daily July 05 2016

Posted onon July 18, 2016
  • Corporate Tax
  • International Tax

NO TDS liability on software purchases on basis of retro-amendment in definition of ‘royalty’

Tenet Tax Daily July 04 2016

Posted onon July 18, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

Commission paid to foreign agent for procuring export orders wouldn’t attract TDS under sec. 195

Tenet Tax Daily July 01 2016

Posted onon July 1, 2016
  • Corporate Tax
  • International Tax

No tax on supply of equipment by foreign Co. just because installation work was done by its Indian subsidiary

Tenet Tax Daily June 27 2016

Posted onon July 1, 2016
  • Corporate Tax
  • International Tax

Sum received by US Co. for services in connection with prospecting for mineral oils is taxable u/s 44BB

Tenet Tax Daily June 22 2016

Posted onon June 25, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

Reimbursement of salary of seconded employees to AE couldn’t be treated as ‘FTS’ to attract TDS under sec. 194J

Tenet Tax Daily June 21 2016

Posted onon June 21, 2016
  • Corporate Tax
  • International Tax

ITAT removes effect of cost reimbursed from AE as comparable wasn’t getting any reimbursement for its services

Tenet Tax Daily June 17 2016

Posted onon June 16, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

An income already assessed to tax in hands of agent couldn’t be taxed in hands of its principal

Tenet Tax Daily June 15 2016

Posted onon June 16, 2016
  • International Tax

Sum received by US co. for providing web hosting service wasn’t royalty, though involving use of scientific equipment

Tenet Tax Daily June 14 2016

Posted onon June 16, 2016

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