Rashmin Sanghvi & Associates

Chartered Accountants

220, 2nd Floor, Arun Chambers,
Tardeo Road,
Mumbai - 400 034,
Maharashtra, India.

Tel. Nos.: (+91 22) 2351 1878, 2352 5694.

Fax : (+91 22) 2351 5275.

Email : [email protected]

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Articles

Taxation

International Taxation

Changes in Tax Residency Rules and interplay with FEMA residential status -		May 2022
Analysis of Section 9 – over 8 hours -		May-June 2021
Overview of International Taxation		31st March 2019
Residence under FEMA and Income-tax
- This article was first published in the The Chamber of Tax Consultants’ journal of June 2018
Trends in International Tax Planning - Way forward		2nd June, 2018
Multilateral Instrument – to curb tax avoidance		20th Jan., 2018
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Digital Taxation

Brain Trust on Digital Taxation		8^th August, 2021
Digital Taxation Our book – “Digital Taxation” was published in November, 2019 by M/s. Taxmann Publications Pvt. Ltd. Almost all books are sold out. Instead of publishing a reprint or new edition, we are making available this book on our website for free download by anyone interested in the subject. Our subsequent articles on the subject and updates will be placed in this chapter of this website. Earlier articles are available in the chapter titled “Electronic Commerce”.		November, 2019

Electronic Commerce

Digital Taxation – Global Trends		5^th October 2019
Tax War – Digital Taxation		18^th April 2019
International Taxation Challenges For Digitalised Economy – Paper & Presentation presented to Mr. P K Mody, Chairman, CBDT and Member – Legal, CBDT, Mr. Akhilesh Ranjan on 11th March 2019:
1. Detailed Paper presented to Shri Akhilesh Ranjan, Member – Legal, CBDT 2. Summary presented to Chairman, CBDT		5^th March 2019 5^th March 2019
Report on Profit Attribution to Permanent Establishments published by CBDT		18^th April 2019
Equalisation Levy – An Analysis		12 July 2016
E-Commerce Committee Report proposing Equalization Levy. (Mr. Rashmin Sanghvi was a member of this Committee.)		21st March, 2016
Taxation of a Global Corporation		March 2013
E-Commerce International Taxation Possible Solutions		1 Dec, 2006
Contents
Part I - Principles
Part II - Conceptual Statement of Problems and Solutions
Part III - Detailed Paper
BPO Taxation in India		27 Feb, 2004
Circular No. 1-2004 issued by CBDT, India		19 Feb, 2004
Circular No. 23 of 1969 issued by CBDT, India		10 Feb, 2004
OECD Reports		5 Oct, 2001
E-commerce and taxation report (by Ministry of Finance of India)		5 Oct, 2001
Taxation of Income derived from e-commerce - India report published for International tax conference at San Francisco		5 Oct, 2001
"Business Connection - R. D. Aggarwal's case"		22 Mar, 2010

Domestic Taxation

TDS provisions including Section 195 - Important developments		April 2022
Succession Planning		14th March, 2018
Demonetisation Explained and Notifications issued till now		12th November 2016
Demonetisation – Representation with regard to difficulties faced by Foreign Tourists & NRIs		9th November 2016

Budget 2020

International Tax Provisions		7th Feb, 2020
Residential Status – Short Version of the Article Finance Act 2020 – changes affecting NRIs.		17th April, 2020
Residential Status - Long version of the article meant for professionals & academicians Finance Act 2020 – changes affecting NRIs.		20th April, 2020

Earlier Budgets

Budget 2017 – Direct Tax Provisions		4th March, 2017
Budget 2016 – Direct Tax Provisions		10th May, 2016
Budget 2016 - Equalisation Levy		29th Feb, 2016
Tax Return Filing for AY 2015-16		29th July, 2015
Budget 2015 – Direct Tax and FEMA Implications		7 April, 2015
I. Attack on Black money II. Tax Residence of foreign companies III. Indirect Transfer Provisions IV. Other Tax provisions V. Deductions for Individuals & HUFs VI. Foreign Exchange Management Act VII. Tax rates
Budget 2014, An Analysis		29 July, 2014
Finance Bill 2012, An Analysis		14 Apr, 2012
Disclosure regarding Foreign Assets		12 Apr, 2012
Budget Note, 2011 - Part I		4 Mar, 2011
Budget Note, 2011 - Part II		4 Mar, 2011
Tax on dividends distributed by Foreign Subsidiaries - An Amnesty Scheme		8 Mar, 2011
Section 94A - Black Listing of Tax Havens		7 Mar, 2011

Black Money Act 2015

Black Money Law - an Analysis		15th Aug, 2015
Black Money Law & Treaty		15th Aug, 2015
Black Money Law & Foreign Discretionary Trust		15th Aug, 2015
Multi-Lateral Attack on Black Money		15th Aug, 2015
1. Black Money Act 2. Rules & Compliance Scheme 3. FAQs on Compliance Scheme 4. 2nd Set of FAQs on Compliance Scheme 5. RBI Press Release on Regularisation of Assets held abroad.

Vodafone

Vodafone Case : Its Consequences		28 Feb, 2012
Vodafone - A Wake up Call		23 Mar, 2009
International Tax Concepts - Vodafone		14 Mar, 2009

Direct taxes Code

Revised Discussion Paper on the Direct Taxes Code		25 Feb, 2011
Direct Taxes Code 2009 An Analysis		4 Feb, 2011
Clarifications on DTC		31 Jan, 2011
A Brief Note on DTC		31 Jan, 2011
Discussion Paper on New Direct Taxes Code		10 June, 2010
Direct Taxes code		22 Mar, 2010

Applicability of GAAR – Fundamental Requirements		28th Sept., 2017
- The article was first published in the journal of The Chamber of Tax Consultants for October 2017
Disruption in Income Taxation		28th Sept., 2017
- The article was first published in the journal of The Chamber of Tax Consultants for October 2017
Indirect sale of Indian assets – Capital Gain		13th Jan 2017
Foreign Tax Credit		17 March, 2017
POEM
Note on Circular providing relief to small companies from POEM		4th March, 2017
Annex 1 - Circular 6 - Guiding Principles for determination of POEM of a Company		24th Jan, 2017
Annex 2 - Press Release - Guiding Principles for determination of POEM of a Company		24th Jan, 2017
Annex 3 - Representation made by us		14th Feb, 2017
Annex 4 – Clarification for determination of POEM of a Company		23rd Feb, 2017
Place of Effective Management – Importance and Precautions		5 May, 2015
Issues on Capital gains and Other Incomes earned by Non-residents		30 April 2016
PE and Attribution of Profits		20 February 2016
TDS on Payments to Non-Residents		31 Oct 2015
Elimination of Double Taxation - Thane		15th July 2015
Taxation of Capital Gains earned by Non-residents		January 2014
Note on Revised Remittance Procedures		October 2013
Morals & Ethics in Taxation		August 2013
Concept of Residence under International Taxation		26 Apr, 2013
Capital Gains and related issues		November 2012
Fundamentals of International Taxation		12 Aug, 2012
Interest, Royalty and Fees for Technical Services		2 July, 2012
Controlled Foreign Corporations (CFC)		25 Feb, 2011
Black Money		4 Feb, 2011
Article 7 - Part I		31 Jan, 2011
Article 7 - Part II		31 Jan, 2011
Impact of Section 206AA on TDS from Payments to Non-Residents		10 June, 2010
Attribution of Profits to Permanent Establishment		22 Mar, 2010
Treaty Override		22-23 Jan, 2010
Payment to a non-resident - TDS obligation		December 2009
Principles of Jurisprudence in International Taxation		25 Sep, 2008
DTA How to read a Tax Treaty - Bangalore		30 Aug, 2008
Taxation of Expatriates		09 Feb, 2008
International Tax Principles Chamber of Tax Consultants		June, 2007
The Chamber of Income-tax Consultants Tax deduction at source from payments to Non-residents		28 May , 2007
Principles of International Taxation Limitations & Possible Solutions		23 Dec, 2006
BPO Taxation In India		27 Feb, 2004
Vienna Convention on the Law of Treaties		10 Sep, 2003
Rashmin's Presentation on Vienna Convention at BMA Conference - 2003		2003
Working Group Report on Non-Resident Taxation Shri Vijay Mathur Committee Report		28 Jan, 2003
Working Group Report on Non-Resident Taxation - Annexure to Appendix III		28 Jan, 2003
Rights and Duties during Income tax search		12 Oct , 2001
OECD Model draft changes for 2002		11 Oct , 2001
CLOSE X

Budget 2005		2005
1. Press Release
(i) Direct Taxes
(ii) Indirect Taxes
2. Our note on Press Releases related to Direct Taxes
Earlier Budgets
Indian Budget 2003 - Income Tax		7 Jun, 2003
Indian Budget - Economy & Philosophy 2002		29 Mar, 2002
Budget 2000-2001		29 Mar, 2000
Detailed Observations on Indian Budget 1999		27 Mar, 1999
1. Direct Tax & Gold Bonds		27 Mar, 1999
2. Indian Economy		27 Mar, 1999
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Immediate Observations on Indian Budget 1999		1 Mar, 1999
Indian Economy and The Budget 1998		5 Aug,1998
Comments by Mr. Chandrakant Sampat		12 Jun, 1998
Overview of the U.S. Budget		8 Jul, 1998
Overview of the U.K. Budget		8 Jul, 1998
Budget 1997		10 jun, 1997
Other Articles
Is it fair to tax non-residents merely on receipts in India?		April 2000
International Tax Planning Opportunities through Mauritius		8 Jul, 1999
Cyril Pereira Ruling by the Authority for Advance Rulings		Jul 1999
Import of design and drawings		5 Dec, 1998
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