Date and Time:
September 14, 2021 4:30 PM - 6:00 PM
September 16, 2021 4:30 PM - 6:00 PM
September 21, 2021 4:30 PM - 6:00 PM
September 23, 2021 4:30 PM - 6:00 PM
September 28, 2021 4:30 PM - 6:00 PM
September 30, 2021 4:30 PM - 6:00 PM
October 5, 2021 4:30 PM - 6:00 PM
October 7, 2021 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 14th, 16th, 21st, 23rd, 28th, 30th September 5th & 7th October, 2021. 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:
- Rajneesh Verma
Associate Partner
BSR & CO LLP
- Kinjesh Thakkar
India Head of International Tax & Transfer Pricing
Linde Engineering
- Vidur Puri
Senior Partner
SCV & Co. LLP
- Shashishekhar Chaugule
Partner, Tax & Regulatory services
Desai Haribhakti & Co
- Deepika Kothari
Chartered Accountant
- Aditya Jain
Chartered Accountant
- Ramesh Ravisankar
Chartered Accountant
- Prashanth Bala
Chartered Accountant
- Girish Sundar
Chartered Accountant
Brochure: IT_V8
Event Timelines
When are the principles of International Tax Attracted?
Does International Tax apply to you if you do not have an office offshore?
• Legal Framework for International Taxation
Sources of International Tax Law
Domestic law provisions
Double Taxation Avoidance Agreements and Structure
Permanent Establishment (in Model Agreements and DTAAs)
Capital Gains
Royalty
Fee for Technical Services
Tax Information Exchange Provisions
Tax Credit / Refund Provisions
Model Tax Treaties and treaty interpretation of DTAAs under VCLT and OECD
Business Connection under Income Tax Act
International Tax Issues in Secondment Arrangements
• Double Taxation Avoidance Agreements
Article 1 – Person
Article 2 - Taxes Covered
Article 3 - General Definition
Article 4- Resident
Article 6 - Income from Immovable Property
Article 8 - Shipping, Inland Waterways Transport and Air Transport
Article 10 – Dividend
Article 11 – Interest
• Article 5 - Permanent Establishment
• Article 7 - Business Profit
• 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
• 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?
• 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:
o Associated enterprise
o International transaction
o Relevance of function, asset and risk (FAR)
o 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)
o Selection of Tested party
o How to choose an appropriate Profit Level indicator (PLI)
o 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
