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International tax ( 138 results )

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Rulings
FC: Swedish Supreme Court decides against constitution of PE basis time gap in unrelated projects despite common executor

Mar 11, 2022
Rulings
ITAT: Baker Hughes’ interest on IT refund taxable at 15%; Not ‘effectively connected with PE’ to attract 40% tax

Mar 10, 2022
Rulings
ITAT: Claim for treaty benefit not rebutted by Revenue, simply relying on domestic tax provisions unsustainable

Mar 09, 2022
Rulings
ITAT: Perfetti's receipts from subsidiary for ICT services, not FTS; Invokes MFN Clause in India-Netherlands DTAA

Mar 07, 2022
Rulings
ITAT: Centralised Reservation & Property Management Services provided to Marriott, not taxable as FTS or Royalty

Mar 05, 2022
Rulings
ITAT: Dismisses batch of 65 appeals, holds no TDS liability on transponder charges for Viacom 18

Mar 05, 2022
Rulings
FC: Trinidad and Tobago's Court of Appeal denies nil withholding on dividend ultimately received by Canadian parent via ‘conduits’

Mar 03, 2022
Rulings
HC: Charter hire payments by L&T for 'tugs & barges' not taxable as royalty, covered by Sec.44BB

Mar 02, 2022
Rulings
ITAT: Pre-shipment inspection & examination of products not taxable as technical & managerial services

Feb 26, 2022
Rulings
FC: Austrian Federal Tax Court warrants resident state to allow credit of taxes paid on income under attribution conflict

Feb 25, 2022
Rulings
ITAT: Autoliv's receipts under sub-contract for coordination with Ford's technical personnel, not FTS under India-US DTAA

Feb 24, 2022
Rulings
ITAT: Payment for time charter of ships made to NRs not chargeable to tax in India

Feb 21, 2022
Rulings
ITAT: Holds Group Management Fee not FTS, applies India-Portugal DTAA by invoking MFN Clause in India-Belgium DTAA

Feb 18, 2022
Rulings
FC: UK Court of Appeal holds treaty provision for Assistance in Tax Collection applicable retrospectively on outstanding tax dues

Feb 18, 2022
Rulings
ITAT: CBDT Circular on MFN Clause transgresses Sec.90(1), neither binding on ITAT nor retrospective

Feb 15, 2022
Rulings
ITAT: Wipro not liable for TDS u/s 195 on sums paid for installation of IVRS equipment & AMC; Follows De Beers ruling

Feb 14, 2022
Rulings
HC: Directs PCIT to decide Hapag Llyod’s revision application involving interplay of DDT & India-Kuwait DTAA

Feb 14, 2022
Rulings
ITAT: Viacom 18 not liable for TDS on transponder fee, relies on Neo Sports ruling

Feb 12, 2022
Rulings
FC: High Court of Eastern Denmark reiterates, interposed entities do not qualify as beneficial owners of interest

Feb 11, 2022
Rulings
HC: Directs withholding at 8% on Google’s receipts as interim measure in dispute over interplay of EL & Royalty/FTS

Feb 07, 2022

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