Product Description
Part I. Taxation of International Transactions and Non -resident Taxation in India (50 Marks)
- 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
- 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)
- Overview of Model Tax Conventions
- OECD Model Tax Convention
- UN Model Tax Convention
- US Model Tax Convention
- 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
- Anti Avoidance Measures
- Controlled Foreign Corporations
- Base Erosion and Profit Shifting
- Other Anti Avoidance Measures
- Taxation of E-Commerce Transactions
- Introduction
- Emerging issues
- Equalization levy
INDEX
| CA_FINAL_International_ELECTIVE_PAPER_INDEX_MAY_2019 | ||
| 01. NR Taxation | ||
| 1 | 00. Important Notice | 0:05:34 |
| 2 | 01 Taxation Of NR | 1:01:26 |
| 3 | 02 Residential Status Part 1 | 1:31:37 |
| 4 | 03 Residential Status Part 2 | 1:17:23 |
| 5 | 04 Place Of Effective Management | 0:52:15 |
| 6 | 04 Place Of Effective Management | 0:55:02 |
| 7 | 06 Incidence Of Tax Part 2 | 1:10:43 |
| 8 | 07 Incidence Of Tax Part 3 | 0:55:44 |
| 9 | 08 Sec 44B to 44BBB | 0:18:03 |
| 11 | 09 Sec 44C and 44DA | 0:36:03 |
| 12 | 10 Sec 48 1st and 4th proviso etc | 0:53:50 |
| 13 | 11 Special Rates for NR Sec 115A etc | 1:08:57 |
| 14 | 12 TDS Provisions | 0:10:49 |
| 02. DTAA | ||
| 1 | Double Taxation Avoidance Agreements | 1:07:19 |
| 03. Transfer Pricing | ||
| 1 | 01 Introduction To Transfer Pricing | 0:10:49 |
| 2 | 02. Sec 92 to 92B | 0:50:51 |
| 3 | 03 Sec 92ba And 92c Cup Method | 1:28:01 |
| 4 | 04 Sec 92c Other Methods And 92ca | 2:02:40 |
| 5 | 05. Sec 92CB and Safe Harbour Rules | 1:05:14 |
| 6 | 06 92cb To 92e | 1:43:03 |
| 7 | 07 TP last part | 2:20:24 |
| 04. Advance Ruling | ||
| 1 | Advance Ruling new | 0:39:20 |
| 05. Equalisation Levy | ||
| 1 | Chapter 5 Equalisation Levy | 0:42:33 |
| 06. Model Tax Conventions | ||
| 1 | 01 Chapter 6 Part 1 | 1:21:17 |
| 2 | 02 Chapter 6 part 2 | 1:02:12 |
| 3 | 03 Chapter 6 Part 3 | 0:30:52 |
| 07. Interpretation of Tax Treaties | ||
| 1 | 01 Chapter 7 part 1 | 1:24:36 |
| 2 | 02 Chapter 7 Part 2 | 1:15:25 |
| 08. BEPS | ||
| 1 | 01 Chapter 8 Part 1 | 1:04:51 |
| 2 | 02 Chapter 8 Part 2 | 1:25:47 |
| 3 | 03 Chapter 8 Part 3 | 1:23:31 |
| Additional Topics | ||
| 1 | 01 Additional Topics part 1 | 0:49:31 |
| 2 | 02 additional Topics Part 2 | 1:00:57 |
| 3 | 03 additional Topics Part 3 | 0:46:41 |
| 4 | 04 additional Topics Part 4 | 0:38:33 |
| 5 | 05 additional Topics Part 5 | 1:12:20 |
| 6 | 06 Additional Topics Part 6 | 0:51:59 |
| 7 | 07 Additional Topics Part 7 | 0:58:21 |
| 8 | 08 Additional Topics part 8 | 0:35:31 |
| 9 | 09 Black Money Act Part 1 | 1:08:22 |
| 10 | 10 Black Money Act part 2 | 0:59:41 |
| 11 | 11 Black Money Act part 3 | 0:32:36 |
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