Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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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