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Importance of Section 90(1) Notification in DTAA: SC s Ruling

Learn why a Section 90(1) notification is crucial for a DTAA's enforcement, as per the Supreme Court's landmark judgment in AO vs. Nestle SA. Understand its impact and implications.

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Benefit of tax credit under Article 23 of Indo-Thai DTAA extended only when tax actually paid

Delhi High Court held that tax credit could not be extended to the assessee, because it had not paid tax in Thailand, i.e., that benefit under Article 23 of the Indo-Thai DTAA could only be extended in a situation where the tax had actually been paid.

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Interest on FCCDs is to be computed by applying LIBOR plus 200 points

ITAT Hyderabad held that FCCDs are debt hence interest paid/ payable on FCCDs in to be computed by applying LIBOR plus 200 basis points.

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IHTM27163 - Foreign property: Double Taxation Conventions: exchange of information: why exchange information? - HMRC internal manual

IHTM27163 - Foreign property: Double Taxation Conventions: exchange of information: why exchange information? - HMRC internal manual
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Taxation of profits realized by foreigners in Brazil and the concept of Permanent Establishment - PE (*)

The definition of the concept of Permanent Establishment - PE stems mainly from the need to minimize possible tax evasion in view of profits…

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