Leaders In Knowledge Dissemination Space
Event Date

INDIA - 17/03/2021 - 10/04/2021

Event Description

Certificate Course On International Tax

About the Event

Achromic Point takes immense pride on its mission of continuing business as usual and thereby announces its Certificate Course on International Tax on 17th, 19th, 25th, 26th March 2nd, 7th, 9th, 10th April, 2021. This certificate program provides the 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 and 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. This course is outlined keeping in mind the recent trend and issues in the field of International Tax and helps you identify the best methods for integrating into the new systems while deriving the most tax benefits.
 
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:

·        Alok Sinha
Associate Director Corporate Business Tax 
BSR & Co
 
·        Rajneesh Verma
Executive Director
Global Transfer Pricing Services
BSR & Co. LLP
  
·        Ananya Kapoor
Advocate (Taxation)
Chambers of Salil Kapoor

·        Vidur Puri
Senior Partner
SCV & Co. LLP
 
·        Palaniappan A
Chartered Accountant
 
·        Prashanth Bala
Chartered Accountant
 
·        Sirish M I
Chartered Accountant
 
·        Ramesh Ravishankar
Chartered Accountant

Event Agenda

 Agenda:

17th March, 2021
11.30 AM - 01.00 PM
 
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?
 
  • 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
 
19th March, 2021
11.30 AM - 01.00 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 6 - Income from Immovable Property
    • Article 8 - Shipping, Inland Waterways Transport and Air Transport
    • Article 10 – Dividend
    • Article 11 – Interest
 
25th March, 2021
05.00 PM - 06.30 PM
 
Session 3: Double Taxation Avoidance Agreements
 
  • Article 5 - Permanent Establishment
  • Article 7 - Business Profit
  • Article 12 - Royalty and Fees for Technical Services
  • Article 13 - Capital Gains
26th March, 2021
11.30 AM - 01.00 PM
 
Session 4: Double Taxation Avoidance Agreements
 
  • 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
 
2nd April, 2021
11.30 AM - 01.00 PM
 
Session 5: 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?
 
7th April, 2021
11.30 AM - 01.00 PM
 
Session 6: 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
9th April, 2021
11.30 AM - 01.00 PM
 
Session 7: Guiding Concepts of Transfer Pricing
 
  • Arms’ Length Pricing and methods
  • Comparable uncontrolled price method (CUP)
  • Resale Price Method
  • Cost-Plus Method
  • Transactional net Margin method(TNMM)
  • Profit Split Method
  • How to choose an appropriate method
  • Role of an advanced pricing agreement
  • Associated Enterprises
  • Permanent Establishment
  • Taxation of Foreign Companies_ PoEM Rules
  • Safe Harbour Rules
  • Place of Effective Management
  • Sample Transfer Pricing Agreement
  • International Tax Issues in Secondment Arrangements
 
10th April, 2021
11.30 AM - 01.00 PM
 
Session 8: 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
 

Date

17/03/2021 - 10/04/2021

Time

Opening Day Time: 11:30 am - 1:00 pm
Closing Day Time: 11:30 am - 1:00 pm

Venue

Webinar

Brochure

Download Link : IT_V11.pdf

Registration Fees

INR 9,000.00

REGISTRATION

Event Calender

March 2021 April 2021