Slump Sale Meaning ‘Slump sale’ meaning, relevant for Section 50B of the Income Tax Act, considers the following important aspects : – There is a transfer of one or more undertaking The transfer may be by any means (for cash consideration or through an exchange of shares/ other form of consideration) The transfer is for … Read more
Elimination of Double Taxation – Article 23 – Double Taxation Avoidance Agreement Applicability of Article 23 – Elimination of Double taxation In many cases, the application of tax Treaty may result into double taxation for tax payers. In such a case, in order to provide relief to such Tax payers, Article 23 provides for the … Read more
Directors Fees – Article 16 – OECD Model tax Convention Taxation of Director’s Fees – Article 16 Article 16 – India USA Treaty Directors’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the Board of Directors of a company which is a resident of … Read more
Meaning of Passive Income In order to ascertain if a company has a Place of Effective Management in India, the Meaning of passive income is an important criterion. A company shall be said to be engaged in ‘Active Business Outside India’ if amongst other conditions, its passive income is 50% (or less) of its total … Read more
Place of Effective Management (POEM) – Meaning When we talk about the meaning of “Place of Effective Management , it is an internationally acceptable test to determine, whether a company incorporated in a foreign jurisdiction, is a tax resident of another country.” Place of effective management means a place where : – Key management, and … Read more
Topics covered under Form 15CB of Income tax act:- When is Form 15CB Required When payment is chargeable to tax Aggregate payment is more than Rs 5 lakhs How to File Form 15CB of Income Tax Act? Filing Form 15CB Online Revision of Form 15CB When is Form 15CB Required Filing (Both condition) When payment … Read more
Form 15CA of Income tax act Reporting under Form 15CA When Form 15CA is Required When to fill Part A of Form 15CA When to fill Part B of Form 15CA When to fill Part C of Form 15CA When to fill Part D of Form 15CA How to file form 15CA How to file … Read more
What is a NO PE Certificate? A No PE Certificate India (also known as No PE declaration Form India ) is required to be furnished by a Non – Resident, who obtains any income from India . The income can be in the nature of following : – Business profits Fee for Technical Services Royalties … Read more
What is Global Minimum Tax? In order to attract international business and investments, tax rates are kept at very low level in many countries. These low tax rates result in an outflow of funds and business from economies that have a proper tax structure in place, to countries with a lower rate of tax or … Read more
Article 28 – Member of Diplomatic Mission and Consular Posts ARTICLE 29– INDIA USA TREATY Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular offices under the general rules of international law or under the provisions of special agreements. CHARACTERISTICS Not related to tax matters Provides protection to fiscal privileges … Read more