CA Final: International Tax (Elective) By CA Farooq Haque

Product Description

Part I. Taxation of International Transactions and Non -resident Taxation in India (50 Marks)

1. Transfer Pricing provisions under the Income -tax Act, 1961

• Arm’s Length Price
• International Transactions
• Most Appropriate Method
• Functions, Assets and Risk Analysis
• Documentation & Compliances
• Specific Reporting Regime in respect of Country by Country reporting and master file
• Advance Pricing Agreements

2.Other Provisions relating to taxation of international transactions and non -resident taxation under the Income-tax Act, 1961

• Non-resident Taxation (including Source Rule of Taxation)
• Double Taxation Relief

(iii) Advance Rulings

3. Law and Procedures under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 – An Overview

Part II:  Other aspects of International Taxation (50 Marks)

1. Overview of Model Tax Conventions

• OECD Model Tax Convention
• UN Model Tax Convention
• US Model Tax Convention

2. Tax treaties, Application and Interpretation

• Features of Tax treaties
• Overview of Tax Information Exchange Agreements
• Commentaries and their importance
• Role of Vienna Convention in application and interpretation of tax treaties

3. Anti Avoidance Measures

• Controlled Foreign Corporations
• Base Erosion and Profit Shifting
• Other Anti Avoidance Measures

4. Taxation of E-Commerce Transactions

• Introduction
• Emerging issues
• Equalization levy