Date and Time:
May 11, 2023 2:00 pm - 6:00 pm
May 12, 2023 2:00 pm - 6:00 pm
Event Location:
Online, India
Description
Achromic Point presents the Certificate Course on International Tax scheduled on 11th & 12th May 2023. 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.
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:
- Rahul Chheda
Associate Director, International Tax
Nexdigm - Mital Patel
Associate Director – Direct Tax
Nexdigm - Nishant Shah
Senior Manager, Global Transfer Pricing,Nexdigm - Harshal Bhuta
Partner
P. R. Bhuta & Co. Chartered Accountants - Ravi Sawana
Associate Partner
Lakshmikumaran & Sridharan - Hardik Mehta
Hardik D Mehta & Co. Chartered Accountants
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: 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
Session 6: 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
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