Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The notification, issued by the Ministry of Finance, pertains to the modification of the Convention between the Government of India and the Kingdom of Spain for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital. It addresses the taxation of royalties and fees for technical services between the two countries. Specifically, it substitutes paragraph 2 of Article 13 of the Convention, limiting the taxation at source on royalties and fees for technical services to ten per cent of the gross amount, provided the recipient is the beneficial owner.
The notification, issued by the Ministry of Finance, pertains to the modification of the Convention between the Government of India and the Kingdom of Spain for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital. It addresses the taxation of royalties and fees for technical services between the two countries. Specifically, it substitutes paragraph 2 of Article 13 of the Convention, limiting the taxation at source on royalties and fees for technical services to ten per cent of the gross amount, provided the recipient is the beneficial owner.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
