Delhi High Court Rules that Reimbursement of Salary Cost for Seconded Employees Constitutes FTS Where Home Entity Retains Lien and Overarching Control
July 7, 2026
The Delhi High Court (HC), on June 18, 2026, in Ernst & Young U.S. LLP (EY US) has, inter alia, ruled that in the given facts, EY US retained ‘lien’ over seconded employees in India and cost-to-cost reimbursements of such seconded employees were taxable as Fees for Technical Services (FTS) under both Section 9(1)(vii) of the Income-tax Act, 1961 (Act), and Article 12 of the India–US Tax Treaty (Tax Treaty).
A&M Tax – Monthly Recap of EU and Dutch Tax Developments
July 6, 2026
The “Monthly Recap” is A&M’s monthly newsletter providing a concise overview of EU and Dutch tax developments.
Trump Accounts (IRC §530A): What High-Income Clients Need to Know Now
July 3, 2026
The One Big Beautiful Bill Act introduces Trump Accounts, a new tax-advantaged savings vehicle for children. While Trump Accounts offer federal seed funding and tax-deferred growth, taxpayers should carefully consider the associated gift tax implications, state tax treatment, and contribution strategy until further guidance is issued.
Update on BOI Progress Report Filing Deadlines
July 3, 2026
The new announcement revises the filing timeline for BOI progress reports. BOI-promoted companies must now submit progress reports quarterly, from the date the BOI promotion certificate is issued until the project receives approval for official commencement of operations.