Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
India notifies the amending Protocol to the India-Brazil tax treaty, which entered into force on 18 October 2025 and is given effect in India under section 90 of the Income-tax Act. The amendments update treaty provisions on residence, permanent establishment, shipping and air transport, dividends, interest, royalties, technical services, capital gains, employment income, artistes and sportspersons, pensions, relief from double taxation, non-discrimination, mutual agreement procedure, and treaty entitlement. The Protocol also introduces detailed anti-abuse rules, including qualified person tests, active business tests, ownership thresholds, principal purpose denial, and protection against treaty-shopping.
India notifies the amending Protocol to the India-Brazil tax treaty, which entered into force on 18 October 2025 and is given effect in India under section 90 of the Income-tax Act. The amendments update treaty provisions on residence, permanent establishment, shipping and air transport, dividends, interest, royalties, technical services, capital gains, employment income, artistes and sportspersons, pensions, relief from double taxation, non-discrimination, mutual agreement procedure, and treaty entitlement. The Protocol also introduces detailed anti-abuse rules, including qualified person tests, active business tests, ownership thresholds, principal purpose denial, and protection against treaty-shopping.
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