Date and Time:
August 10, 2022 10:00 am - 3:00 pm
Event Location:
Online, India
Description
Webinar on BEPS and MLI on 10th August 2022. Timing: 10.00 AM – 03.30 PM
Thought Leader:
- Shashishekhar Chaugule
FCA, Insolvency Professional, Registered Valuer - Sanjana Hegde
Principal
Dhruva Advisors - Chetna (Naik) Thapar
Director| Corporate and International Tax
B S R & Co LLP
Event Timelines
Session 1:
· Basic introduction on what lead to Introduction of BEPS, What is BEPS?
· What lead to introduction of MLI?
· How to read MLI etc.
Session 2
· 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]
India’s position with respect to the same
Session 3:
· 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)
· India’s position
Interplay between GAAR and PPT
Session 4:
· Other anti-avoidance measures [Dividend and Capital Gain on immovable property [Action Plan 6 of BEPS] (Articles 8 and 9 of MLI) India’s position
Break
Session 5
· Artificial avoidance of PE status through Commissionaire and Agency arrangements
· Artificial avoidance of PE status through specific activity exemptions and anti-fragmentation rules, Preparatory and Auxiliary activity Exemption
[Action Plan 7 of BEPS] [Article 12,13 of MLI]
Session 6:
· 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
· India’s Position
Session 7:
India’s domestic measures to address BEPS