Date and Time:
June 21, 2022 2:00 PM - 3:30 PM
June 21, 2022 3:30 PM - 5:00 PM
June 22, 2022 2:00 PM - 3:30 PM
June 22, 2022 3:30 PM - 5:00 PM
June 23, 2022 2:00 PM - 3:30 PM
June 23, 2022 3:30 PM - 5:00 PM
Event Location:
Online, Online, India
Description
Achromic Point pleased to invite you to our Certificate Course on International Tax scheduled on 21st, 22nd & 23rd June 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 structuring for global businesses, 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:
- Parth Savla
Principal
Dhruva Advisors - Sanjana Hegde
Principal
Dhruva Advisors - Vidur Puri
Senior Partner
SCV & Co. LLP - Shashishekhar Chaugule
FCA, Insolvency Professional, Registered Valuer - Saurabh Shah
Principal
Dhruva Advisors - Priyanka Jain
Associate Partner
Vaish Associates Advocates
Event Timelines
Session 1: Introduction to International Tax:
§ 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?
Session 2: International Tax Treaties:
· 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
Session 3: International Tax Treaties:
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
Session 4: BEPS and MLI:
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
Session 5: Guiding Concepts of Transfer Pricing:
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
Comparable uncontrolled price method (CUP)
Resale Price Method (RSM)
Cost-Plus Method (CPM)
Profit Split Method (PSM)
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
Session 6: Penalties and Dispute Resolution:
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
