Description
Achromic Point presents the Certificate Course on International Tax scheduled on 29th May 2024. 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
AGENDA:
| 10.00 AM – 10.45 AM |
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? |
| 10.45 AM – 12.00 PM |
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
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- 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
|
| 12.00 PM – 01.00 PM |
Session 3: 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
|
| 01.00 PM – 01.30 PM |
Break |
| 01.30 PM – 02.30 PM |
Session 4: 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
|
| 02.30 PM – 03.45 PM |
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
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THOUGHT LEADERS:
