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INTERNATIONAL TAX - Budget 2015

Tax in General + Budget + Finance Acts - By: - CS Swati Dodhi - Dated:- 2-3-2015 Last Replied Date:- 30-12-1899 - INTERNATIONAL TAX Reduction in rate of tax on Income by way of Royalty and Fees for technical services in case of non-residents The existing provisions of section 115A of the Act provide that in case of a non-resident taxpayer, where the total income includes any income by way of Royalty and Fees for technical services (FTS) received by such non-resident from Government or an Indian .....

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certain cases It is proposed to provide that, in the case of a non-resident, being a person engaged in the business of banking, any interest payable by the permanent establishment in India of such non-resident to the head office or any permanent establishment or any other part of such non-resident outside India shall be deemed to accrue or arise in India and shall be chargeable to tax in addition to any income attributable to the permanent establishment in India and the permanent establishment .....

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lowance of interest claimed as expenditure by the PE and may also attract levy of interest and penalty in accordance with relevant provisions of the Act. These amendments shall be effective from April 1, 2016. Determining residency status in respect of Companies It is proposed to amend the provisions of section 6 to provide that a person being a company shall be said to be resident in India in any previous year, if: - It is an Indian company; or - Its place of effective management (POEM), at any .....

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