International Taxation Case Studies – Transfer Pricing and Non Resident Taxation – by CA Arinjay Jain International Taxation Case Studies, which can be accessed from the links below, are in respect of certain practical situations, that arise during the course of conducting international business. The case studies have been prepared keeping in mind, the existing … Read more
Interest paid by a Foreign Bank Branch to overseas HO and other Branch – Non Resident Taxation – International Taxation Case Study LLM Bank Ltd. carrying on banking business is incorporated in Melbourne, Australia. It has branches in different countries including India. During financial year 2018-19, the Indian branch of the bank paid interest of … Read more
NRI returning to India and continuing to have overseas income – International Taxation Case Study Peeyush, a Non-Resident Indian returned to India on 12th June, 2018 for permanently residing in India after a stay of about 20 years in U.K., provides the sources of his various income and seeks your opinion to know about his … Read more
Taxation of Non-resident sportsperson , is dealt with in Section 115BBA of the Income Tax Act, 1961, which provides that the following incomes of non-resident sportsman (including an athlete), who is a foreign citizen are taxable at 20%: Income from participation in India in any game (other than winnings from crossword puzzles, races including horse … Read more
Computing value of Assets for application of POEM Test – Non Resident Taxation – International Taxation Case Study A company shall be said to be engaged in ‘Active Business Outside India’ for the purpose of POEM, if amongst other conditions, less than 50% of its total asset are situated in India. From the following Balance … Read more
Power to hold that POEM of Non resident is in India – Non Resident Taxation – International Taxation Case Study XYZ BV, a company based out of Netherlands, executed certain infrastructure projects in India from 2014 – 2019. It had been filing its income tax return as a non-resident, due to which the beneficial provision … Read more
Salary earned in India and Article 15 short stay exemption – Non Resident Taxation – International Taxation Case Study Joseph Clarke, an Australian resident, worked in India on a construction Project, which constituted a PE of the employer in India. For the India work where he was present for 160 days and he earned a … Read more
Company engaged in operations of Aircraft – Non Resident Taxation – International Taxation Case Study GetSetGo Airways is engaged in operation of aircraft and leased certain aircraft from Goeing UK. During the year, the various payment made by GetSetGo Airways to Goeing UK, were as under : – Nature Amount Tax on Income Total Payment … Read more
Corporate restructuring overseas – Non Resident Taxation – International Taxation Case Study Sunio Japan, is a global company, which has subsidiaries in various countries. Five of its subsidiaries , hold 100% share capital of Sunio India, which were acquired by them at various cost over the years. The group undertook Corporate restructurings in FY 2018-19, … Read more
Adjustment and Scope of Assessment – Advance Pricing Agreement – Transfer Pricing – International Taxation Case Study AB India Private Limited was incorporated under Companies Act, 2013, at Mumbai, and is a subsidiary of USA based company AB Inc. It is engaged in providing asset management software, namely, OPAC, to Indian clients. Such software can … Read more