Date and Time:
February 21, 2022 4:30 PM - 6:00 PM
February 22, 2022 4:30 PM - 6:00 PM
February 23, 2022 4:30 PM - 6:00 PM
February 24, 2022 4:30 PM - 6:00 PM
February 25, 2022 4:30 PM - 6:00 PM
February 26, 2022 4:30 PM - 6:00 PM
Event Location:
Online, India
Description
Achromic Point pleased to invite you to our Certificate Course on International Tax scheduled on 21st, 22nd, 23rd, 24th, 25th & 26th February, 2022. This certificate program will provide an opportunity to prove and improve you or your team’s credentials as an International Tax Professional which is crucial in a global business environment where transactions with customers and suppliers often transcend national borders investment and activities are frequently cross-border as well.
An understanding of the international tax rules is of paramount importance to a wide variety of tax and corporate professionals. In this we will be discussing upon the recent trend and issues in the field of International Tax, International tax Treaties, Legal Framework for International Taxation, BEPS and MLI, Case studies and much more.
Who should attend?
CFO/CA/CS, Head, Vice President, President, Director, General Manager, Manager of
- International Taxation
- Tax Litigation
- Transfer Pricing
- Direct Taxation
- Financial Controllers
- Finance Shared services
Thought Leaders:
- Teenu Mathew
Chartered Accountant - Neeraj Jain
Partner
Vaish Associates Advocates - Priyanka Jain
Principal Associate
Vaish Associates Advocates
- Debojit Mahanta
Chartered Accountant
- Rajneesh Verma
Associate Partner
BSR & Co. LLP - Divya Yadav
BSR & Co. LLP - Vidur Puri
Senior Partner
SCV & Co. LLP
Brochure: ITR brochure_V2
Event Timelines
When are the principles of International Tax Attracted?
Does International Tax apply to you if you do not have an office offshore?
• International Tax Planning:
International tax structuring for global businesses
Case study of India - Mauritius DTAA
How Foreign Tax Credit Works
International Tax Structuring and Tax Havens
Why the amended Mauritius India DTAA will not impact foreign investment
Do Commissionaire arrangements constitute a PE?
• Double Taxation Avoidance Agreements:
Article 1 – Person
Article 2 - Taxes Covered
Article 3 - General Definition
Article 4- Resident
Article 5 - Permanent Establishment
Article 6 - Income from Immovable Property
Article 7 - Business Profit
Article 8 - Shipping, Inland Waterways Transport and Air Transport
Article 10 – Dividend
Article 11 – Interest
Article 12 - Royalty and Fees for Technical Services
Article 13 - Capital Gains
Article 21 - Other Income
Article 23 - Methods of Elimination of Double Taxation
Article 24 - Non-Discrimination
Article 25 - Mutual Agreement Procedure
Article 26 - Exchange of Information
• Transparent Entities, Dual Resident Entities and application of methods of elimination of double taxation because of such mismatch [Action Plan 2 of BEPS] [Article 3, 4, and 5 of MLI]
• Prevention of Treaty abuse - Preamble to the DTA, Principal Purpose Test (PPT), Limitation of Benefit [Action Plan 6 of BEPS] (Articles 6 and 7 of MLI)
• Interplay between GAAR and PPT
• Other anti-avoidance measures [Dividend and Capital Gain on immovable property [Action Plan 6 of BEPS] (Articles 8 and 9 of MLI)
• [Action Plan 7 of BEPS] [Article 12,13 of MLI]
• Artificial avoidance of PE status through specific activity exemptions and anti-fragmentation rules, Preparatory and Auxiliary activity Exemption [Articles 13 and 15 of MLI]
• Splitting of contracts [Construction PE – Articles 14 and 15 of MLI
• Applicability of TP provisions
• Scheme of TP provisions in India:
Associated enterprise
International transaction
Relevance of function, asset and risk (FAR)
Selection of most appropriate methods
o Comparable uncontrolled price method (CUP)
o Resale Price Method (RSM)
o Cost-Plus Method (CPM)
o Profit Split Method (PSM)
o Transactional net Margin method (TNMM)
Selection of Tested party
How to choose an appropriate Profit Level indicator (PLI)
Base Erosion and Profit Shifting (BEPS) Compliances
• Accountant’s report
• Dispute resolution mechanism
• Secondary adjustment
• Limitation of interest deduction- Section 94B
• Penalties under Indian domestic law
• Tax avoidance and tax evasion
• General Anti-Avoidance Rule (GAAR) and Special Anti-Avoidance Rule FATCA
• Information exchange provisions
• International cooperation under DTAAs
• Tax Information Exchange Agreements (TIEAAs)
• How to safeguard against future regulatory risks - Authority for Advanced Rulings (AAR)
• Settlement of disputes with tax authorities
• Transfer pricing disputes in offshore jurisdictions
