Recent content by asilgulsar

I also have a similar requirement to collect payments using local systems in UAE and Saudi whereas we have an Indian Company.

I work in Manohar Chowdhry & Associates. You can obtain more details from the below website. http://www.mca.co.in/

A CA will be able to help you with this, especially since it involves Indian income-tax. The firm I work with specialises in international taxation assignments, and I am sure we will be able to assist. Please let me know if you are interested.

I'm close to obtaining the CPA equivalent (CA) in India. So, still a student in International tax.

I agree with you. But the point I was trying to make was that they were trying to 'show' control in another country when it was actually in the country of residence. If the trustee actually controls the assets then, POEM cannot be established in the country of residence.

We had a litigation in India where the tax payer had made a trust in one country, appointed a bank as trustee, and the trustee held the underlying companies incorporated in a third country through another step down entity. The directors of the underlying companies were non-individuals...

You are right. I had replied earlier under the wrong assumption that the company is incorporated in the US but managed in India. Assuming the following to be the facts: i) Company is incorporated outside of India and not in US; ii) Management is from India (Board meeting held in India and key...

Since the income is derived in US and assuming board meeting and commercial decisions are taken in India, the company will become a tax resident in both the countries and will have to pay taxes in both. India-USA DTAA does not stipulate a tie-breaker rule for residency of companies, therefore...