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Direct Taxation

August 2026

what-are-the-tax-complexities-of-cross-border

Introduction

Picture of by Anjali Darak
by Anjali Darak

Manager - Direct Tax

Cross-border secondment arrangements are widely used by multinational groups to facilitate knowledge transfer, governance oversight, strategic project execution and workforce mobility across jurisdictions. However, Indian tax authorities increasingly examine the substance of these arrangements to determine the true employer relationship and associated tax consequences. Therefore, businesses must carefully assess PE exposure, withholding tax obligations, GST implications, treaty benefits and compliance requirements before implementing a secondment structure.

Coming to this month’s, Taxation Times, here’s what we have:

  1. An article on “Tax Complexities of Cross-Border Secondment in India”
  2. Case Laws from various courts & jurisdictions
  3. Tax Compliance Calendar – August 2026
  4. Circulars & Notifications – July 2026
  5. Tax News from around the world

We hope that you find this month’s edition of the Taxation Times useful. In case you have any feedback or need us to include any information to make this issue more informative, please feel free to write to us at info@uja.in

Happy Reading!

Best Regards,
UJA Tax Team

What are the Tax Complexities of Cross-border Secondment in India?

1. Introduction

Cross-border secondment arrangements have become an integral component of multinational business models. Global organizations frequently deploy personnel across jurisdictions to facilitate knowledge transfer, strengthen governance, implement group policies, support strategic projects and bridge talent gaps.

In recent years, Indian tax authorities and courts have increasingly focused on the substance of secondment arrangements rather than their contractual characterization.

Consequently, businesses must carefully evaluate the economic employer relationship, tax treaty implications, Permanent Establishment (PE) risks, withholding tax obligations, GST exposure & compliance requirements before implementing a secondment structure.

Understanding Cross-Border Secondment

A cross-border secondment typically involves an employee of a foreign entity being temporarily assigned to work with an Indian group company or vice versa.

The principle objectives generally include:

  • Transfer of technical expertise and know-how
  • Implementation of global business processes
  • Leadership development and succession planning
  • Standardization of group-wide policies
  • Operational support for strategic projects

Types of Secondment

  • Inbound Secondment – Under an inbound secondment arrangement, an employee of a foreign company is deputed to an Indian company.
    For example: Foreign Parent Company → Employee → Indian Subsidiary
  • Outbound Secondment – Under an outbound secondment arrangement, an employee of an Indian company is deputed to a foreign group entity.
    For example: Indian Company → Employee → Overseas Affiliate

Parties Involved and Their Key Objectives

Foreign Entity – The foreign entity generally seeks to:

  • Deploy skilled personnel globally
  • Ensure implementation of group-wide policies
  • Maintain consistency in business processes
  • Support strategic business initiatives

Host Entity – The host entity aims to:

  • Access specialised expertise
  • Improve operational efficiencies
  • Facilitate knowledge transfer
  • Strengthen management capabilities

Seconded Employee – The employee typically benefits through:

  • International work exposure
  • Technical and professional development
  • Enhanced career prospects
  • Cross-cultural experience

Types of Employers in a Secondment Arrangement

A key issue in every secondment arrangement is determining whether the foreign entity continues to be the employer or whether the Indian entity assumes the role of the real (economic) employer.

The different types of employers and their respective roles and responsibilities are discussed below:

Legal Employer – The legal employer usually:

  • Retains the employment contract
  • Pays salary and benefits
  • Administers payroll
  • Maintains employment lien
  • Provides retirement and social security benefits

Economic / Real Employer – The economic employer is the entity that:

  • Exercises day-to-day supervision
  • Controls and directs work activities
  • Evaluates performance
  • Bears economic costs and risks associated with employment

Key Challenges in Cross-Border Secondment

  • Determining whether the foreign entity or the host entity is the real/economic employer of the secondee.
  • Assessing whether salary reimbursements are mere cost recoveries or consideration for services provided by the foreign entity.
  • Evaluating whether the presence and activities of secondees create a taxable PE for the foreign enterprise in India.
  • Determining whether the arrangement constitutes an employer–employee relationship or a taxable manpower supply service.
  • Ensuring compliance with visa, FRRO, social security and provident fund requirements applicable to international assignments.

Landmark Judicial Decisions

  • Director of Income Tax (International Taxation), Mumbai v. Morgan Stanley & Co. Inc. (Supreme Court, 2007)
    The Supreme Court held that stewardship and monitoring functions alone do not result in a Permanent Establishment in India. The determination depends upon actual functions performed and control exercised over the personnel.
  • Centrica India Offshore Pvt. Ltd. v. Commissioner of Income Tax-I & Ors. (Delhi High Court, 2014)
    The Court held that salary reimbursements may constitute FTS where:
    • The foreign company retains employment lien; and
    • The secondees provide technical expertise to the Indian entity.

The judgment emphasized that substance should prevail over contractual form.

  • Commissioner of Central Excise and Service Tax, Bangalore (Adjudication) & Ors. v. Northern Operating Systems Pvt. Ltd. (Supreme Court, 2022)
    The Supreme Court held that secondment arrangements could amount to manpower supply services where the foreign company continues to remain the actual employer and the reimbursements effectively represent consideration for provision of personnel.
    This remains one of the most significant decisions governing the GST and service tax implications of secondments.
  • M/s Flipkart Internet Pvt. Ltd. v. Deputy Commissioner of Income Tax (Karnataka High Court, 2022)
    The Court observed that reimbursement of salary costs does not automatically become taxable as FTS. Where the applicable treaty contains a “Make Available” clause, the transfer of technical knowledge must be specifically established.
  • Commissioner of Income Tax (International Taxation)-1, New Delhi v. Ernst & Young U.S. LLP (Delhi High Court, 2026)

In a significant recent ruling, the Delhi High Court held that reimbursements received by EY US from Indian group entities in respect of deputed employees were taxable as FTS under the India-US DTAA.

The Court observed that the foreign entity retained employment lien over the secondees and that EY methodologies, technical processes, and know-how were transferred to the Indian entities, thereby satisfying the “Make Available” requirement.

The decision reinforces the Revenue’s position that cost-to-cost reimbursement may nevertheless be taxable where technical expertise is transferred and the foreign enterprise continues to maintain substantive employment rights.

Frequently Asked Questions (FAQ)

It depends on the actual functions performed and control exercised over the employee, not just the contractual arrangement. As held by the Supreme Court in Morgan Stanley (2007), mere stewardship or monitoring activities do not create PE. However, if the foreign entity retains significant control over the seconded employee’s work, PE exposure may arise.

Not automatically. Courts have held that pure cost reimbursement isn’t inherently taxable as Fees for Technical Services (FTS). However, per Centrica (2014) and the recent Ernst & Young US LLP (2026) ruling, if the foreign company retains the employment lien and technical expertise / know-how is transferred to the Indian entity, the reimbursement can be taxed as FTS, especially where the treaty has a “Make Available” clause.

The real (economic) employer is determined by who exercises day-to-day supervision, controls work activities, evaluates performance, and bears the economic risk of employment, not simply who pays the salary or holds the contract. This distinction is central to most tax and GST disputes in this area.

Yes. The Supreme Court in Northern Operating Systems (2022) held that if the foreign company continues to be the actual employer and reimbursements effectively represent payment for supplying personnel, the arrangement can be classified as manpower supply services, attracting GST or service tax.

Ensure robust documentation, clearly define roles and responsibilities between the foreign and host entities, evaluate FTS and PE exposure under applicable treaties, and — most importantly, ensure your actual business conduct matches your contractual terms. Courts increasingly look at substance over form, so consistency between paperwork and practice is critical.

Conclusion

Cross-border secondment arrangements sit at the intersection of employment law, income-tax law, GST, immigration regulations, social security rules and international tax treaties. Recent judicial developments demonstrate that Indian courts are increasingly focused on identifying the real employer, assessing control and supervision, evaluating knowledge transfer & examining the economic substance of arrangements.

The rulings in Centrica, Northern Operating Systems, Flipkart & Ernst & Young US LLP collectively establish that there is no universal tax treatment for secondment arrangements. Each arrangement must be independently evaluated based on its facts, contractual terms, operational realities and treaty provisions.

Accordingly, multinational groups should ensure robust documentation, clear allocation of responsibilities, proper evaluation of FTS and PE exposure and consistency between contractual arrangements and actual business conduct to effectively manage tax and litigation risks arising from cross-border secondments.

Planning a cross-border secondment? Let UJA Global Advisory help you get the structure, documentation & compliance right.

Case Laws

July 2026
[2026] 188 taxmann.com 167 (Gujarat) HIGH COURT OF GUJARAT [06-07-2026] Vinod Parsotam Rabara vs. Income-tax Officer

Facts :

  • The assessee, along with other co-purchasers, purchased a portion of land bearing Survey No. 31, by a registered sale deed dated 03-04-2021.
  • A search under section 132 was conducted on 28-09-2021 at the premises of B Safal Group and City Estate Management India, a real estate broker. During the search, an inquiry register containing a noting dated 29-11-2018 relating to Survey No. 31 and mentioning an asking rate of Rs. 1.20 crore per vigha was seized.
  • Based on this entry, the Assessing Officer alleged that the assessee had paid on-money of Rs. 4.89 crore over and above the consideration recorded in the sale deed and issued a notice under section 148.
  • On writ petition:

Held I:

  • On the basis of the aforesaid entry in the seized inquiry register, the Assessing Officer formed the opinion that the assessee had paid on-money of Rs. 4.89 crore on the purchase of land bearing Survey No. 31 at Village Kaneti and accordingly sought to reopen the assessment year 2022-23. [Para 9]
  • The first and foremost aspect which strikes on a perusal of the seized material is the date of the noting in the inquiry register. The date of the noting is 29-11-2018, which falls in Assessment Year 2019-20. However, the assessee purchased the land bearing Survey No. 31 at Village Kaneti by registered sale deed dated 03-04-2021 – i.e., approximately twenty-eight months after the date of the noting. The entry in the register, therefore, predates the actual purchase transaction of the assessee by a very considerable period. In this background, the entry dated 29-11-2018 can, at best, be viewed as a market survey reflecting the asking rate for land available for sale in Village Kaneti as on that date. Notably, the statement of Shri Pravin Nagjibhai Bavadiya recorded under Section 131 of the Income Tax Act, 1961 himself confirms that the inquiry registers contain details of “land/plots available for sale at different locations near Ahmedabad”. Since the purchase transaction by the assessee was executed approximately twenty-eight months after the date of the register entry, the noting cannot be treated as a record of any transaction executed by the assessee. Moreover, the register entry falls in the period of Assessment Year 2019-20 and is wholly incapable of imputing escapement of income for Assessment Year 2022-23, which is the year sought to be reopened. [Para 10]
  • Even on the question of the evidentiary weight to be attached to the seized inquiry register, the revenue’s case is materially weakened by the admissions made by Shri Bavadiya himself during his statement recorded in the course of the search. At Question No. 14, Shri Bavadiya candidly admitted that sometimes clients come with land documents or title deeds and these belonged to the clients and not to him. This admission directly and significantly undermines the blanket presumption under Section 292C that all entries in the inquiry register necessarily record actual financial transactions carried out by or through Shri Bavadiya. Further, at Question No. 26, it emerges that the ‘owner of the land’ is typically the person whose name is entered in the register—confirming that the name reflected therein is that of the owner or broker who listed the property, and not necessarily a party who paid or received any undisclosed consideration. These specific admissions by the searched person himself effectively negate the foundation upon which the revenue has sought to invoke a generalised presumption under Section 292C to treat the inquiry register entries as conclusive evidence of on-money transactions involving the assessee. [Para 11]
  • It is further noted that the register entry relates to the entire land bearing Survey No. 31 admeasuring 11,152 sq. mtr. (4.69 vigha). However, the assessee along with co-purchasers purchased only a portion of this land, and the remaining 2,025 sq. mtr. continues to remain under the ownership of the original sellers and did not form part of the assessee’s purchase transaction. The register entry thus covers an area considerably larger than the actual extent of land purchased by the assessee, and this discrepancy further militates against any live connection between the seized register entry and the assessee’s transaction. [Para 12]
  • The name “Sanjay Thakor” appearing in the seized inquiry register is of a person who is entirely unconnected to and unknown by the assessee. The assessee has specifically pointed out that no inquiry whatsoever has been conducted by the Department from Sanjay Thakor, whose name actually appears in the register. The Assessing Officer has drawn satisfaction in the case of the assessee based on the same register entry while completely ignoring the person whose name appears therein, without making any inquiry from said person. Furthermore, the statement of Shri Pravin Nagjibhai Bavadiya recorded under the provisions of Section 131 does not in any manner mention the name of the assessee or the co-purchasers. Thus, no direct or indirect link is found between the assessee and the seized document. The revenue has attempted to reopen the assessment year 2022-23 only on the basis of some vague information allegedly connected from the seized document, which does not in any manner relate to the present assessee. [Para 13]
  • Even otherwise, this issue is no more res integra as the same is covered in favour of the assessee by the judgement of this Court in the case of Naliniben Jagdishkumar Gandhi v. ITO [2026] 183 taxmann.com 126 (Gujarat). This Court has, after considering a similar entry in the same customer inquiry register seized in the same search, held as follows: “Except the seized documents as mentioned herein-above, and the statements of the searched person Shri Bavadiya, there is no material recorded by the Assessing Officer which would reveal the name of the assessee. It is true that cash transactions operate in very clandestine manner, and the re-assessment cannot be quashed, but the revenue has to prove a live link connecting the assessee. The only link is the survey number of the assessee.” [Para 14]
  • The aforesaid principle applies with equal, if not greater, force to the present case, where not only is there no live link between the seized register entry and the assessee’s transaction, but the entry itself suffers from the multiple infirmities and internal contradictions noticed hereinabove. [Para 15]
  • Hence, the assessment has been sought to be reopened on the basis of conjectures and surmises. The seized inquiry register entry does not establish any live nexus with the assessee. There is no direct or indirect link between the seized document and the present assessee. The invocation of the proceedings under Section 148 is ill-conceived and unsustainable. Accordingly, the captioned writ petition stands allowed. The impugned notice issued under Section 148 is hereby quashed and set aside. [Para 17]
  • In Favour of: The assessee
[2026] 188 taxmann.com 351 (Delhi - Trib.) IN THE ITAT DELHI BENCH 'DB' [10-07-2026]
Sandeep Thakur vs. Income-tax Officer

Facts :

The assessee claimed deduction under section 80G amounting to Rs. 8.30 lakhs. The Assessing Officer disallowed the claim, initiated penalty proceedings under section 270A, and subsequently levied penalty under the said provision.

  • The assessee contended that, while initiating and levying penalty, the Assessing Officer failed to specify the particular clause under section 270A(9) under which the case was treated as one of ‘misreporting of income’, rendering the penalty proceedings invalid.
  • The assessee challenged the penalty before the Commissioner (Appeals) both on merits and on the technical ground that the Assessing Officer had not identified the specific limb of section 270A(9). The Commissioner (Appeals), by order passed under section 250, upheld the Assessing Officer’s action.
  • On appeal to the Tribunal, the assessee reiterated that the penalty was invalid as the Assessing Officer had failed to specify the applicable limb under section 270A(9) for alleging misreporting of income, while the revenue supported the orders of the lower authorities.

Held II:

  • The Tribunal, after considering the submissions and the documents on record including the authorities relied upon by the assessee, finds that coordinate bench orders are directly on the point that a fatal infirmity is brought into penalty proceedings under section 270A when the exact limb of section 270A(9) is not specified. In this regard, the relevant portion from the Delhi High Court in Prem Brothers Infrastructure LLP v. National Faceless Assessment Centre ([2022] 142 taxmann.com 38/288 Taxman 768 (Delhi)) is relied upon wherein it is held that in absence of finding on particulars as to which limb of section 270A is attracted and how the ingredient of sub-section (9) of section 270A is satisfied, the mere reference to the word ‘misreporting’ by the respondents in the penalty order to deny immunity from imposition of penalty and prosecution makes the impugned order manifestly arbitrary. Respectfully following this order, it is held that the impugned penalty is manifestly illegal and deserves to be struck down. [Para 3]
  • In the result, the appeal of the assessee is allowed. [Para 4]
  • In Favour of: The Assessee
[2026] 188 taxmann.com 293 (Mumbai - Trib.) IN THE ITAT MUMBAI BENCH 'J' (SMC) [07-07-2026]
Satinder Govind Oberai v. Income-tax Officer

Facts :

The assessee, an individual, filed her return for A.Y. 2017-18 declaring total income of about Rs. 0.69 lakh from salary and interest. Her case was selected for scrutiny on account of cash deposits of Rs. 11.40 lakh made in three bank accounts during the demonetisation period. She explained that the deposits represented marriage gifts received on her marriage solemnised on 1-5-2016, past savings and cash retained at home for medical contingencies relating to her specially-abled step-son and ailing mother-in-law.

  • During assessment, the assessee furnished confirmations in support of part of the deposits. The AO accepted the explanation to the extent of Rs. 4.51 lakh and treated the balance Rs. 6.89 lakh as unexplained money under section 69A taxable under section 115BBE.
  • On appeal, the CIT(A) upheld the addition of Rs. 6.89 lakh under section 69A read with section 115BBE and dismissed the assessee’s appeal.
  • On appeal to the Tribunal.

HELD:

  • It is an undisputed fact that the assessee deposited cash aggregating to Rs.11.40 lakhs in her three bank accounts during the demonetization period. The assessee explained that the source of the cash comprised marriage gifts received at the time of her marriage solemnized on 1-5-2016, past savings, and cash retained at home to meet any medical emergency concerning her specially-abled step-son and ailing mother-in-law. During the assessment proceedings, the Assessing Officer accepted the explanation to the extent of Rs.4.51 lakhs based on the confirmations produced by the assessee and treated only the balance amount of Rs.6.89 lakhs as unexplained under section 69A. It is found that the assessee’s marriage, held only a few months prior to the demonetization period, is an undisputed fact. It is also not uncommon in Indian social customs for a bride to receive gifts in cash from relatives and well-wishers on the occasion of marriage and to retain such cash for future household or medical contingencies. The explanation furnished by the assessee regarding retention of cash for the medical needs of her specially-abled stepson and ailing mother-in-law cannot be rejected merely on the basis of conjectures, particularly when no material has been brought on record by the revenue to establish that the impugned cash represented income from any undisclosed source. The revenue has also not found any evidence of unaccounted business activity or any other incriminating material to contradict the explanation offered by the assessee. The addition has been sustained primarily on the ground that the assessee could not produce complete documentary evidence for the entire amount and that there was a time gap between the marriage and the deposits made during the demonetization period. It is viewed that these circumstances alone are insufficient to invoke the provisions of section 69A when the explanation is otherwise plausible and is supported by surrounding circumstances. The mere retention of cash for a few months before its deposit due to demonetization cannot, by itself, render the explanation unbelievable. Considering the totality of the facts and circumstances of the case, it is opined that the assessee has furnished a reasonable and satisfactory explanation regarding the source of the impugned cash deposits. Accordingly, the addition of Rs.6.89 lakhs made under section 69A and taxed under section 115BBE is directed to be deleted. The grounds raised by the assessee are, therefore, allowed. [Para 5]
  • In the result, the appeal of the assessee is allowed. [Para 6]
  • In Favour of: The Assessee

Circular & Notifications July 2026

A. Circular

CONDONATION OF DELAY IN FILING FORM NO. 10AB ELECTRONICALLY FOR APPROVAL UNDER CLAUSE (ii) OF THE FIRST PROVISO TO SECTION 80G(5) OF THE INCOME-TAX ACT, 1961,
CIRCULAR NO. 6/2026 [F. NO. 300176/3/2026-ITA-I], DATED 2-7-2026
  1. Section 80G of the Income-tax Act, 1961 (“the Act”) provides for deduction in respect of donations made to certain funds and institutions. For availing approval under clause (ii) of the first proviso to section 80G(5) of the Act, a fund or institution approved under section 80G(5) and whose approval is due to expire, is required to furnish an application in Form No. 10AB electronically, at least six months prior to expiry of the said period.
  2. Representations have been received in the Board from certain funds and institutions whose approval was expiring on 31.03.2026 and who could not furnish Form No. 10AB for seeking approval under clause (ii) of the first proviso to section 80G(5) of the Act within the due date of 30.09.2025.

It has been represented that the delay in furnishing the prescribed application was attributable to bona-fide reasons and other circumstances resulting in genuine hardship to the funds or institutions in terms of receipt of donations.

  1. The matter has been examined by the Board. In order to mitigate genuine hardship to such funds and institutions, the Central Board of Direct Taxes, in exercise of the powers conferred under section 119(2)(b) of the Income Tax Act, 1961, read with section 536(2) of Income Tax Act, 2025, hereby condones the delay in filling Form No. 10AB, where the prescribed application in Form No.10AB has been furnished electronically between 01.10.2025 to 31.03.2026. The jurisdictional Principal Commissioner of Income-tax or Commissioner of Income-tax are authorized to dispose of such applications on merits and pass an order on or before 31.12.2026.
  2. Further, where an application in Form No. 10AB filed electronically between 01.10.2025 to 31.03.2026 has been rejected as on date of issue of this circular solely on the ground that it was furnished beyond the prescribed time limit of 30.09.2025, the delay shall be deemed to have been condoned in such cases. The jurisdictional Principal Commissioner of Income-tax or Commissioner of Income-tax are authorized to dispose of such applications on merits and pass an order on or before 31.12.2026.
  3. Nothing contained in this Circular shall be construed as conferring any automatic entitlement to approval under section 80G(5) of the Act or section 133(1)(b) of I.T. Act, 2025, as the case may be.

A. Notifications

Notification No. 81/2026/F. No. 225/77/2026/ITA-II New Delhi,
Dated 10-07-2026

S.O. 3759(E).—In pursuance of section 258(1)(b) of Income-tax Act, 2025, the Central Government hereby  specifies  Principal  Secretary,  Cooperation,  Marketing  and  Textile  Department,  Government  of Maharashtra for the purposes of the said section in connection with sharing of information regarding income-tax payers’ for identifying eligible beneficiaries under the Punyashlok Ahilyadevi Holkar Farmer Loan Waiver Scheme, 2026.

NOTIFICATION NO. 85/2026/F. No.85/2026/F.No.370149/112/2026
Dated 15-07-2026

S.O. 3889(E).—In exercise of the powers conferred by section 72(8)(a) of the Income-tax Act, 2025 (30 of 2025), the Central Government hereby specifies the Cost Inflation Index as mentioned in column (3) of the Table below for the Financial Years mentioned in the corresponding entry in column (2) of the said Table, namely:

Sl. No.

Financial Year

Cost Inflation Index

(1)

(2)

(3)

1

2026-27

384

2.This notification shall apply to the tax year 2026-27 on and from the 1stday of April, 2026 and subsequent tax years.

C. Office Memorandum

CLARIFICATORY FREQUENTLY ASKED QUESTIONS (FAQs) RELATED TO TRANSITION PROVISIONS UNDER SECTION 536 OF THE INCOME-TAX ACT, 2025 (REPEALS AND SAVINGS ), OFFICE MEMORANDUM F. NO. 370149/107/2026 –TPL, DATED 6-7-2026

Various representations are received by TPL Division since Income-tax Act, 2025 has come into force from 01.04.2026 requesting to furnish comments/inputs seeking clarification related to transition provisions under section 536.

  1. In this regard, the undersigned is directed to forward the FAQs related to section 536 of the Income Tax Act, 2025 as per Annexure, for necessary action towards its issuance/publication.
  2. This issue with the approval of the Member(L), CBDT.

Tax Calendar August 2026

07th August 2026

  • Form 127: Declaration under section 394(2) of the Act to be made by a buyer for obtaining goods without collection of tax received in the month of July, 2026.
  • Statutory Forms Filling Due Date: Due date for deposit of Tax deducted/collected for the month of July, 2026. However, all sum deducted/collected by an office of the government shall be paid to the credit of the Central Government on the same day where tax is paid without production of an Income tax Challan.

14th August 2026

  • Form 132: Due date for issue of Certificate under section 395(4) for tax deducted at source in the month of June, 2026.

15th August 2026

  • Form 1: Monthly statement to be furnished by a stock exchange in respect of transactions in which client codes been modified after registering in the system for the month of July, 2026.
  • Form 131: Certificate under section 395(4) for tax deducted at source other than on salary paid to an employee under section 392 or pension or interest income of specified senior citizen under section 393(1) for the quarter ending June 30, 2026
  • Form 133: Certificate under section 395(4) for tax collected at source for the quarter ending June 30, 2026.
  • Form 137: Due date for furnishing of Form 137 by an office of the Government for TDS/TCS Book Adjustment Statement for the month of July, 2026. 

30th August 2026

  • Form 141: Due date for furnishing of Challan-cum-statement of deduction of tax under section 393(1) [Table Sl. No. 2(i), 3(i), 6(ii) and 8(vi)] in the month of July,
  • Form 3CEF: Annual Compliance Report on Advance Pricing Agreement (if due date of submission of return of income is July 31, 2026).

31st August 2026

  • All Income tax returns: Return of income for the Assessment Year 2026-27 in the case of assessee (a) non-corporate assessee (having income from business or profession and whose books of account are not required to be audited under or under any other Act) or (b) working partner of a firm whose accounts are not required not to be audited under this Act or under any other Act or the spouse of such partner if the provisions of section 5A applies to such spouse or
  • All Income tax returns: Payment of Self-Assessment Tax (if due date of submission of return of income is August 31, 2026.
  • Form 56FF: Particulars to be furnished under clause (b) of sub-section (1B) of section 10A of the Income-tax Act, 1961 (if due date of submission of return of income is August 31, 2026).
  • Form 10CCD: Certificate under sub-section (3) of section 80QQB for authors of certain books in receipt of royalty income, etc. (if due date of submission of return of income is August 31, 2026).
  • Form 10CCE: Certificate under sub-section (2) of section 80RRB for Patentees in receipt of royalty income, etc. (if due date of submission of return of income is August 31, 2026).
  • Form 10FC: Authorization for claiming deduction in respect of any payment made to any financial institution located in a Notified jurisdictional area. (if due date of submission of return of income is August 31, 2026).
  • Form 3CFA: Form for opting for taxation of income by way of royalty in respect of Patent (if due date of submission of return of income is August 31, 2026).
  • Form 3CT: Income attributable to assets located in India under section 9 of the Income-tax Act, 1961 (if due date of submission of return of income is August 31, 2026).
  • Form 10BBC: Certificate of accountant in respect of compliance to the provisions of clause (23FE) of section 10 of the Income-tax Act, 1961 by the notified Pension Fund.
  • Form 10BBD: Statement of eligible investment received (if due date of submission of return of income is August 31, 2026).
  • Form 5C: Details of amount attributed to capital asset remaining with the specified entity (if due date of submission of return of income is August 31, 2026).
  • Form 10BA: Declaration to be filed by the assessee claiming deduction under section 80GG (if due date of submission of return of income is August 31, 2026).
  • Form 10E: Form for furnishing particulars of income under section 192(2A) for claiming relief u/s 89 (if due date of submission of return of income is August 31, 2026).
  • Form 10-EE: Taxation of income from retirement benefit account maintained in a notified country (if due date of submission of return of income is August 31, 2026).
  • Form 10H: Certificate of foreign inward remittance (if due date of submission of return of income is August 31, 2026).
  • Form 10IA: Certificate of the medical authority for certifying person with disability, severe disability, autism, cerebral palsy and multiple disability for purposes of section 80DD and section 80U (if due date of submission of return of income is August 31, 2026).
  • Form 10-IEA: Application for exercise of option under clause (i) of sub-section (6) of section 115BAC or withdrawal of option under the proviso to sub-section (6) of section 115BAC of the Income-tax Act, 1961 (if due date of submission of return of income is August 31, 2026).
  • Form 10IG: Statement of Exempt income under clause (4D) of section 10 of the Income-tax Act, 1961 (if due date of submission of return of income is August 31, 2026)
  • Form 10IH: Statement of income of a Specified fund eligible for concessional taxation under section 115AD of the Income-tax Act, 1961 (if due date of submission of return of income is August 31, 2026).
  • Form 10-II: Statement of exempt income under clause (23FF) of section 10 of the Income-tax Act, 1961 (if due date of submission of return of income is August 31, 2026).
  • Form 10-IK: Annual Statement of Exempt Income under sub-rule (2) of rule 21AJA and taxable income under sub-rule (2) of rule 21AJAA (if due date of submission of return of income is August 31, 2026).
  • Statutory Forms Filling Due Date: Statement by scientific research association, university, college or other association or Indian scientific research company as required by rules 5D, 5E and 5F (if due date of submission of return of income is August 31, 2026).
  • Form 10: Statement to be furnished to the Assessing Officer/Prescribed Authority under clause (a) of the Explanation 3 to the third proviso to clause (23C) of section 10 or under clause (a) of sub-section (2) of section 11 of the Income-tax Act, 1961 (if the assessee is required to submit return of income on October 31, 2026).
  • Form 9A: Application for exercise of option under clause (2) of the Explanation to sub-section (1) of section 11 of the Income – tax Act, 1961 (if the assessee is required to submit return of income on October 31, 2026).

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Uruguay Expands Taxation of Foreign-Source Investment Income

Uruguay published implementation guidance for its revised personal income tax regime applicable to certain foreign-source income and gains earned through non-resident entities.

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Canada Transfer Pricing Landmark Decision

In ExxonMobil Canada Resources Company v. The King, the Tax Court of Canada issued extensive guidance on transfer pricing principles.

The decision addresses:

  • Functional analysis
  • Economic analysis
  • Deductibility of feasibility study costs
  • Recharacterization standards

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