Some Indian DTAAs with Germany, USA, United Kingdom, Australia, New Zealand, Sweden, etc. define a “resident” under Article 4(1) as a person who is liable to tax in that State by reason of domicile, residence, citizenship, or similar criteria, b̲u̲t̲ ̲d̲o̲e̲s̲ ̲n̲o̲t̲ ̲i̲n̲c̲l̲u̲d̲e̲ ̲a̲n̲y̲ ̲p̲e̲r̲s̲o̲n̲ ̲w̲h̲o̲ ̲i̲s̲ ̲l̲i̲a̲b̲l̲e̲ ̲t̲o̲ ̲t̲a̲x̲ ̲i̲n̲ ̲t̲h̲a̲t̲ ̲S̲t̲a̲t̲e̲ ̲i̲n̲ ̲r̲e̲s̲p̲e̲c̲t̲ ̲o̲n̲l̲y̲ ̲o̲f̲ ̲i̲n̲c̲o̲m̲e̲ ̲f̲r̲o̲m̲ ̲s̲o̲u̲r̲c̲e̲s̲ ̲i̲n̲ ̲t̲h̲a̲t̲ ̲S̲t̲a̲t̲

One of the criteria for designing cross-border corporate structures is also considering the tax exemptions/deductions and incentives the...

After Singapore based fintech startups ‘Pine Labs’ and ‘Phone Pe’ redomiciled their holding companies back to India, the wealth...

In a cross-border ESOP scenario, Indian resident employees are typically granted ESOPs by the foreign parent MNC which are taxable as...

Notices have been issued by Tax Department on major Indian telecom operators (ITOs) on the ground that payments of Inter Connecting User...