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Author : Amar Mehta
Publisher :
ISBN 13 : 9789350710456
Total Pages : 800 pages
Book Rating : 4.7/5 (14 download)
Download or read book Taxmann's Permanent Establishment in International Taxation written by Amar Mehta and published by . This book was released on 2012 with total page 800 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : The Chamber of Tax Consultants
Publisher : Taxmann Publications Private Limited
ISBN 13 : 9390128854
Total Pages : 35 pages
Book Rating : 4.3/5 (91 download)
Download or read book Taxmann's Permanent Establishment Emerging Trends – Complete Guide for Resolution of Complexities Involved in the Concept of Permanent Establishment | October 2020 Edition written by The Chamber of Tax Consultants and published by Taxmann Publications Private Limited. This book was released on 2020-11-17 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: The study of Permanent Establishment has emerged as intriguing and complex subject. This book serves as a complete guide for resolution of complexities involved in the concept of permanent establishment. The structure of the book is as follows: • This book opens up with ‘adaptation of Indian domestic tax laws’ to the ‘global trend’ • The advent of ‘Significant Economic Presence’ and its ramification on the changing concept on business connection has been deliberated in this book • Evolution of permanent establishment (‘PE’) in the e-world • Insights into Multilateral Conventions (‘MLI’) & OECDs position on the changing garb of PE • The book closes with the impact of changing philosophy of PE in the international tax space & in the domestic tax legislature. The contents of the book are as follows: • Introduction • Territorial nexus becomes aerial • Adaptation of Indian Domestic Laws • PE in digital economy • PE under Data Localisation Regime • Server as PE • Modification in Agency PE definition • Modification in Independent agent definition • Preparatory or auxiliary activities • Construction PE – Journey, Abuse and Remedy • Conclusion • Annexures 𝚘 Relevant Provisions of the Act 𝚘 OECD Model Convention (Relevant extract) 𝚘 PE Articles under various treaties 𝚘 Relevant Articles of Multilateral Conventions 𝚘 MLI Impact on PE Article of treaties extracted in Part III
Author : The Chamber of Tax Consultants
Publisher : Taxmann Publications Private Limited
ISBN 13 : 9390628903
Total Pages : 39 pages
Book Rating : 4.3/5 (96 download)
Download or read book Taxmann’s International Taxation – A Compendium | 5,200+ Pages | 200+ Experts | 137 Articles | 4 Volumes | 4th Edition written by The Chamber of Tax Consultants and published by Taxmann Publications Private Limited. This book was released on 2021-02-10 with total page 39 pages. Available in PDF, EPUB and Kindle. Book excerpt: CTC’s International Tax Compendium is a collection of incisive & in-depth articles on international taxation, which serves as a reference manual and indeed, a practice guide for its readers. The current edition of the compendium is more current, more incisive, covers a broader range of topics, and like its previous three editions, promises to be another very useful tool for the following: • Tax Professionals both in India and Overseas • Judiciary and Tax administrators ought to find this a useful reference point both for technical analysis as well as for understanding the right perspective in which to view some of the international tax developments of the recent past. This compendium will equip its readers with better knowledge and practical examples to be able to serve their clients better. The current edition of the compendium is a comprehensive four volumes set, containing approximately 5,200+ pages covering all major topics on the subject of International Taxation, such as: • Amendments made in the Income-tax Act, 1961 • Changes introduced in the OECD Model Tax Convention, 2017 • Updates introduced in the OECD Model Commentary in 2017 • Updates introduced in UN Model Tax Convention in 2017 • Global Focus on combating Tax Evasion • Initiation of various Anti Avoidance Measure and tightening of Anti Money Laundering Laws • Implementation of Multilateral Instruments pursuant to the publication of the BEPS Action Plan Reports in October, 2015. The Present Publications is the 4th Edition, covering 137 Articles authored by 200+ Experts. This Compendium is a balanced collection of articles by recognised experts in the field, by young as well as eminent professionals and also by experienced and knowledgeable Commissioners of Income-tax & Senior Ex- Revenue Officials. This book is divided into four volumes, and their contents (volume-wise) are listed below: • Volume 1 & 2 contains articles explaining the following: 𝚘 Theme/basic concepts of Double Tax Avoidance Agreements 𝚘 Various Articles of Model Tax Convention 𝚘 Specific provisions of the Domestic Law dealing with the Taxation of Non-Residents and Cross-Border Transactions • Volume 3 contains industry specific articles such as: 𝚘 Taxation of Telecom Sector 𝚘 Broadcasting & Telecasting industries 𝚘 Electronic Commerce 𝚘 Foreign Banks, Offshore Funds, FII’s etc. • Volume 4 contains articles on the following: 𝚘 FEMA and other Domestic Laws such as Prevention of Money Laundering Act, Foreign Contribution Regulation Act, Black Money Act, Benami Law 𝚘 Various Anti-Avoidance Measures & other specialised articles
Author : Hans-Jörgen Aigner
Publisher :
ISBN 13 : 9783707305531
Total Pages : 560 pages
Book Rating : 4.3/5 (55 download)
Download or read book Permanent Establishments in International Tax Law written by Hans-Jörgen Aigner and published by . This book was released on 2003 with total page 560 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Michael Kobetsky
Publisher :
ISBN 13 : 9781139144827
Total Pages : 470 pages
Book Rating : 4.1/5 (448 download)
Download or read book International Taxation of Permanent Establishments written by Michael Kobetsky and published by . This book was released on 2014-05-14 with total page 470 pages. Available in PDF, EPUB and Kindle. Book excerpt: The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
Author : Taxmann
Publisher : Taxmann Publications Private Limited
ISBN 13 : 939083161X
Total Pages : 16 pages
Book Rating : 4.3/5 (98 download)
Download or read book Taxmann's Equalisation Levy Commodities Transaction Tax & Securities Transaction Tax with Rules - Annotated & Amended text as Amended by the Finance Act, 2021 | 2021 Edition written by Taxmann and published by Taxmann Publications Private Limited. This book was released on 2021-04-05 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a compilation of all the Laws on the following: • Equalisation Levy with Rules • Commodities Transaction Tax with Rules • Security Transaction Tax with Rules The Present Publication is the Latest Edition, as amended by the Finance Act 2021. This book incorporates the following statutory materials: • Equalisation Levy 𝚘 Arrangement of Sections 𝚘 Text of Equalisation Levy as amended by the Finance Act, 2021 𝚘 Notification u/s 164 of the Finance Act, 2016 • Equalisation Levy Rules, 2016 𝚘 Arrangement of Sections 𝚘 Text of Equalisation Levy Rules, 2016 as amended upto date • Commodities Transaction Tax 𝚘 Arrangement of Sections 𝚘 Text of Commodities Transaction Tax as amended upto date • Commodities Transaction Tax Rules, 2013 𝚘 Arrangement of Sections 𝚘 Text of Commodities Transaction Tax Rules, 2013 as amended upto date • Securities Transaction Tax 𝚘 Arrangement of Sections 𝚘 Text of Securities Transaction Tax as amended by the Finance Act, 2021 • Securities Transaction Tax Rules, 2004 𝚘 Arrangement of Sections 𝚘 Text of Securities Transaction Tax Rules, 2004 as amended upto date • Also Available 𝚘 [4th Edition] of CTC’s International Taxation – A Compendium (Set of 4 Vols.) | 5,200 Pages | 200+ Experts | 137 Articles | This book is a collection of incisive & in-depth articles on international taxation, which serves as a reference manual and indeed, a practice guide for its readers 𝚘 Roy Rohatgi on International Taxation | Provides in-depth treatment of the key topics in international taxation, building up from detailed explanation of the basic concepts, all the way to soldi analysis pf the complex transactional issues 𝚘 [2021 Edition] of Taxmann’s Taxation of Expatriate Employees & Regulatory Aspects | Comprehensive commentary to understand the tax & regulatory aspects of cross-border movement of employees (secondment arrangements), for both expatriates & company 𝚘 CTC’s Permanent Establishment – Emerging Trends | Complete guide for resolution of complexities involved in the concept of permanent establishment 𝚘 Taxmann’s International Taxation Digest | Comprehensive digest of decisions of Supreme Court, High Courts, ITAT and AAR on tax treaties and international taxation, arranged as per Articles of OECD Model Tax Conventions
Author : Jérôme Monsenego
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041192697
Total Pages : 483 pages
Book Rating : 4.0/5 (411 download)
Download or read book International Taxation in a Changing Landscape written by Jérôme Monsenego and published by Kluwer Law International B.V.. This book was released on 2019-05-31 with total page 483 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Prof. Wiman is one of the founding members of EATLP, former chairman of EATLP and former vice president of IFA. The essays cover various topics in the field of international tax law, with a major focus on corporate taxation, an area to which Prof. Dr Bertil Wiman has dedicated most of his research. The book includes authoritative analyses by acknowledged experts on several key international tax topics, which illustrates the growing complexity of this area together with its rapid evolution. The book contains analyses of key international topics, such as: the tax challenges of the digitalisation of the economy; the resolution of international tax disputes; the principles for the taxation of corporations; EU tax law; transfer pricing; and tax treaty law. The depth of the essays contained in this book mirrors the importance of the contributions of Prof. Dr Bertil Wiman to the international tax community. It will also prove of great value to policymakers, tax practitioners and academics.
Author : Andrew Lymer
Publisher : Springer Science & Business Media
ISBN 13 : 9781402071577
Total Pages : 338 pages
Book Rating : 4.0/5 (715 download)
Download or read book The International Taxation System written by Andrew Lymer and published by Springer Science & Business Media. This book was released on 2002-08-31 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403533641
Total Pages : 234 pages
Book Rating : 4.4/5 (35 download)
Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Author : CA Daksha Baxi
Publisher : Taxmann Publications Private Limited
ISBN 13 : 9364558014
Total Pages : 38 pages
Book Rating : 4.3/5 (645 download)
Download or read book Taxmann's International Taxation Ready Reckoner – India's first 'ready reckoner' designed to simplify cross-border tax complexities with practical guidance, case studies, etc. written by CA Daksha Baxi and published by Taxmann Publications Private Limited. This book was released on 2024-09-23 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is India's first 'ready reckoner' specifically focused on the complexities of international taxation and cross-border transactions. It provides comprehensive coverage of essential topics, including the basic provisions of India's taxation scheme, the concept of residence, and the crucial role of Double Taxation Avoidance Agreements (DTAA). The book also discusses the interaction between DTAAs and the Income-tax Act, guiding how to read a DTAA, determine eligibility, and resolve conflicts between a DTAA and domestic tax laws. This handbook is helpful for tax professionals, legal advisors, tax practitioners, tax officers and businesses dealing with cross-border transactions, such as payments to non-residents, transactions involving non-residents, digital transactions, and the withholding tax obligations of residents. The second edition has been updated with the latest amendments from the Finance (No. 2) Act, 2024, and features expanded discussions, additional material, more case studies, and judicial precedents, providing in-depth analysis and practical insights into international taxation. The Present Publication is the 2nd Edition and has been amended by the Finance (No. 2) Act, 2024. This book has been authored by CA Daksha Baxi & Adv. Surajkumar Shetty, with the following noteworthy features: • [Comprehensive Coverage] Covering a broad spectrum of topics, the book details the basic provisions, residential status, the role and application of Double Taxation Avoidance Agreements (DTAA), and their interaction with the Income-tax Act. It provides a step-by-step guide on how to read a DTAA, determine eligibility, and resolve conflicts between DTAA and the Income-tax Act • [In-depth DTAA Analysis] It examines multiple DTAAs to demonstrate how tax implications can vary across treaties or remain consistent, providing clear explanations for these outcomes. This detailed analysis helps readers understand the nuanced application of DTAAs in various cross-border scenarios • [Detailed Chapter Organisation] The chapters are organised to cover different types of income and transactions, such as rental income, business income, dividends, interest, royalties, technical services, capital gains, employment, and more. This structure brings together all relevant provisions of the Income-tax Act, including appropriate cross-references, making navigation straightforward for users • [Taxability Evaluation] The book provides comprehensive guidance on evaluating the taxability of cross-border transactions using the Income-tax Act, DTAA and references to rules, forms, circulars, and landmark judicial precedents. This holistic approach equips readers to assess tax implications accurately and effectively • [Practical Guidance for Advisors] Throughout the book, notes provide valuable insights into how advisors should approach transactions, the investigations required, and the application of the principles of the Income-tax Act and DTAA. This practical advice helps professionals offer sound, informed guidance on cross-border tax matters • [Simplified Explanations] Complex concepts such as Place of Effective Management (PoEM), Permanent Establishment (PE), and business connections are explained in simple language, supplemented with practical examples and judicial precedents. Relevant statutory texts are reproduced verbatim for easy reference, aiding readers in understanding and applying the law • [Special Focus on Investment Structures] The book discusses the taxation of Foreign Portfolio Investors and various investment funds, including Alternative Investment Funds (AIFs), Infrastructure Investment Trusts (InvITs), Real Estate Investment Trusts (REITs), and Securitisation Trusts. It specifically addresses scenarios involving non-resident investors in these structures • [Litigation and Compliance] It provides an overview of provisions related to litigation proceedings under the Income-tax Act, Mutual Agreement Procedures (MAP) under DTAA, the Authority for Advance Rulings (AAR), equalisation levy, transfer pricing provisions, general anti-avoidance rules (GAAR), and special provisions for International Financial Services Centres (IFSC). This comprehensive coverage ensures professionals are well-prepared for compliance and dispute resolution • [Illustrative Case Studies] To enhance practical understanding, the book includes numerous illustrations, practical examples, and comprehensive case studies. These are designed to cover various aspects of cross-border transactions, providing readers with insights into the subtleties and practical challenges involved The structure and layout of the book is as follows: • [25 Well-structured Chapters] dedicated to a specific area of international taxation, including detailed discussions on relevant provisions and practical guidance • [Cross-references] to other chapters where necessary, ensuring clarity and ease of navigation and enhancing the reader's ability to understand complex interrelationships within tax laws • [Appendix] includes formats for relevant forms, updates on withholding tax rates, summaries of abbreviations, and comprehensive lists of withholding tax rates under India's existing DTAAs, serving as a practical toolkit for professionals The contents of the book are as follows: • Tax System for Non-Residents in India – An Overview • Tax Treaties • Setting Up a Business in India • Classification of Income • Determining Eligibility to Claim Benefits of DTAA • Taxation of Rental Income • Taxation of Business Income • Taxation of Dividend Income • Taxation of Interest Income • Taxation of Royalty Income • Taxation of Income from Fees for Technical Services • Taxation of Capital Gains • Taxation of Employment Income • Taxation of Non-Resident Indian • Taxation of Foreign Portfolio Investors • Taxation of AIFs, REITs, InvITs, Securitisation Trust • Transactions Attracting Transfer Pricing Regulations • Business Reorganisations • Discontinuance of Business and Dissolution of Indian Company • Foreign Tax Credit • Making Payments to NRs & Obtaining Lower Withholding Certificate • Assessments, Appeals and Dispute Resolution • General Anti-Avoidance Rules • Miscellaneous • Case Study to Determine Taxability of NR, under the IT Act & DTAA
Author : CA Ashish Karundia
Publisher : Taxmann Publications Private Limited
ISBN 13 : 9390831415
Total Pages : 28 pages
Book Rating : 4.3/5 (98 download)
Download or read book Taxmann’s Taxation of Expatriate Employees & Regulatory Aspects – Comprehensive Commentary (along-with Case Studies) on Cross-Border Movement of Employees | As Amended by the Finance Act 2021 written by CA Ashish Karundia and published by Taxmann Publications Private Limited. This book was released on 2021-05-14 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive commentary to understand & comply with the taxation and regulatory aspect of the cross-border movement of employees, that results in secondment. As with any cross-border arrangement, multiple complex laws are involved, this book serves as a primer to understand these complexities and related compliances. The discussion in this book starts with determining who is the employer of the expatriate, which is important to identify the correct laws to be complied with. This book aims at providing the reader, an insight into implications that typically arise in secondment arrangement(s), under various Indian laws in the hands of the expatriate & company, such as: • Expatriate 𝚘 Immigration Laws 𝚘 Personal Income Tax 𝚘 Custom Baggage Rules • Company 𝚘 Social Security Laws 𝚘 Exchange Control Laws 𝚘 Corporate Income Tax 𝚘 Transfer Pricing 𝚘 Goods & Services Tax 𝚘 Corporate Law The Present Publication is the 2nd Edition, authored by Ashish Karundia, with the following noteworthy features: • [Explains Situs of Accrual of Salary], i.e. place of enforcement of employment contract or place of the rendering of services • [Social Security Deduction] Discusses taxability as well as deductibility of contribution to overseas social security contribution in the hands of the employee • [Disputed Salary Ingredients] Captures detailed analysis of disputed salary ingredients such as: 𝚘 Per-Diem/Per-Day Allowance 𝚘 Tax Equalization 𝚘 Hypothetical Tax 𝚘 Employee Stock Option Plan(s) • [Short Stay Exemption] Explains the conditions for short stay exemption and related issues • [Employment Visa vs. Business Visa] Points out the difference between employment visa and business visa • Explains various clauses such as detachment, exportability and totalization of social security agreements • [Meaning of Resident] Lucidly explains the difference between ‘resident’ as per income-tax and ‘resident’ as per FEMA • [Deemed International Transactions] Explains whether secondment agreement will qualify as deemed international transaction or not • [Case Laws] for deciding the employer employee relationship. • Explains situations when fixed establishment (GST) of the foreign entity is triggered The detailed contents of the book are as follows: • Introduction 𝚘 Overview 𝚘 Employer-Employee Relationship • Implications in the Hands of Employee 𝚘 Immigration Laws 𝚘 Personal Income Tax 𝚘 Custom Baggage Rules • Implications in the Hands of Company 𝚘 Social Security Laws 𝚘 Exchange Control Laws 𝚘 Corporate Income Tax 𝚘 Transfer Pricing 𝚘 Goods and Services Tax 𝚘 Corporate Law
Author : Asif H. Qureshi
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041184775
Total Pages : 963 pages
Book Rating : 4.0/5 (411 download)
Download or read book The Public International Law of Taxation written by Asif H. Qureshi and published by Kluwer Law International B.V.. This book was released on 2019-05-22 with total page 963 pages. Available in PDF, EPUB and Kindle. Book excerpt: The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.
Author : Dr. G. Gokul Kishore
Publisher : Taxmann Publications Private Limited
ISBN 13 : 9357780149
Total Pages : 64 pages
Book Rating : 4.3/5 (577 download)
Download or read book Taxmann’s Cross-Border Transactions under Tax Laws & FEMA – Practical Commentary covering Income Tax (including International Tax & Transfer Pricing), GST, Customs & FEMA, etc., with Case Laws written by Dr. G. Gokul Kishore and published by Taxmann Publications Private Limited. This book was released on 2023-05-26 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides practical guidance based on judicial interpretation of the law and rules. It also provides an easy-to-understand commentary (with departmental clarifications) on cross-border transactions with respect to the following laws: • Income Tax (including International Tax & Transfer Pricing) • Goods & Services Tax (GST) • Customs • Foreign Exchange Management Act (FEMA) This book will be helpful for practitioners, members of the bar & bench and industry, and assessing officers. The Present Publication is the 3rd Edition, amended by the Finance Act 2023 and updated till 1st May 2023. This book is authored by Dr. Gokul Kishore & R. Subhashree, with the following noteworthy features: • [Easy-to-Understand Practical Commentary] covering: o Income Tax (including International Tax & Transfer Pricing) § Implications of International Transactions § Adoption of Appropriate Transfer Pricing (TP) § Comprehending the Creation of Permanent Establishment (PE) and Double Taxation Avoidance Arrangements (DTAA) § Ensuring Compliance with Withholding Obligations when payment is made to non-resident § Issues relating to Royalty & Fees for Technical Services (FTS), Tax Residency and Foreign Tax Credit (FTC) o GST § Examination of Cross-Border Services by applying Place of Supply & Export of Service provisions under the Integrated Goods and Services Tax Act (IGST), besides analyzing benefits to exporters o Customs § Valuation of Imported Goods under Customs Valuation Rules, when transaction value as declared by importer is not accepted § Availing Customs Duty Exemptions § Duty Remission and Rewards under various Export Promotion Schemes as provided in Foreign Trade Policy 2023 o FEMA § Compliance with Provisions of FEMA on Receipts and Payments for Export and Imports • [Exhaustive Discussion on both Basic Concepts and Issues faced by the Industry] combined with essential commentary on statutory provisions and the jurisprudence. • [Cross-references to other Chapters] wherever implications need to be understood The structure of the book is as follows: • [Chapter 1 | Customs Valuation] discusses Article VII of GATT, Customs Valuation Agreement, Section 14 of Customs Act, 1962, Customs Valuation Rules (for imported goods) and Export Valuation Rules with relevant judgments and orders. Pointers relating to transfer pricing issues have also been mentioned in this chapter • [Chapter 2 | Transfer Pricing] analyzes international transactions, associated enterprises, comparables, methods of determining Arms Length Price, TP challenges in India as per the UN TP Manual and judicial rulings, creation of marketing intangibles and TP issues relating to AMP expenses. TP assessment, adjustment and appellate remedy have also been included. To provide a 360° perspective, secondary adjustment, Country by Country Reporting (CbCr), thin capitalization, Cost Contribution Arrangements, intra-group services and cost-sharing arrangements have been succinctly covered • [Chapter 3 | Permanent Establishment & DTAAs] discusses taxing powers and sources of income. The concept of PE and types of PE have been explained through the relevant articles in various DTAAs, along with treatment by the Indian judiciary and ITAT. The attribution of profits to PE, which has significant practical implications, has also been discussed • [Chapter 4 | Incomes other than Business Income, Withholding Obligations and Foreign Tax Credit] is broad-based and to the extent relevant to cross-border transactions; it provides a commentary laced with practical guidance on residency, the definition of interest, jurisdiction to tax, dividends paid or received, taxation of royalty, FTS, salary, capital gains, other income, withholding obligations, FTC, the requirement to file the return and the concept of the representative assessee • [Chapter 5 | Import & Export under IGST Act] as applicable to import and export of goods, import of services and export of services, along with the provisions on the place of supply and refund mechanism, forms the fifth chapter • [Chapter 6 | Customs Exemption and Export Promotion Schemes under FTP] Considering the relevance to cross-border trade, Customs Duty exemptions and export promotion schemes under Foreign Trade Policy 2023 (FTP) have been discussed in the sixth chapter. • [Chapter 7 | Export and Import under FEMA & Regulations] Knowledge of obligations and provisions applicable to export and import under FEMA and regulations thereunder is integral to cross-border transactions. Therefore, a concise commentary on the same has been provided in Chapter 7 • [Chapter 8 | Dispute Resolution] Dispute resolution mechanisms under IGST Act and Customs Act, along with alternative dispute resolution under Income Tax Act, have been included. Chapter 8 also provides a broad overview of the statutory remedies available to exporters and importers
Author : Philip F. Postlewaite
Publisher :
ISBN 13 :
Total Pages : 868 pages
Book Rating : 4.:/5 (319 download)
Download or read book International Taxation written by Philip F. Postlewaite and published by . This book was released on 1995 with total page 868 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Michael Lang
Publisher :
ISBN 13 : 9788171944620
Total Pages : 504 pages
Book Rating : 4.9/5 (446 download)
Download or read book Taxation Of Artistes And Sportsmen In International Tax Law written by Michael Lang and published by . This book was released on 2008-09-01 with total page 504 pages. Available in PDF, EPUB and Kindle. Book excerpt: Some artistes and sportsmen are 'flying birds'. Especially very famous artistes and sportsmen spread their activity - and thus their income-across several countries. Still, normally they do not have a qualified connection - a permanent establishment in the state of performance or a presence fulfilling the criteria of the 183-days rule-to the state of source. Therefore, the OECD introduced a special rule for artistes and sportsmen.Practical experience shows that cross border activities of artistes and sportsmen cause a lot of issues. Issues are caused by the interpretation of the special rule in tax treaties and their interdependence with other treaty provisions. Besides that, artistes and sportsmen are often confronted with discrimination in the state of source. Last but not least, artistic and sportive activities cause specific VAT issues. This volume strives to analyse these issues and to give conclusions based on the interpretation of current international tax law. Furthermore, the authors intend to show how international tax law could be improved where an improvement seems necessary.
Author : D P Mittal
Publisher :
ISBN 13 : 9788184780215
Total Pages : 3552 pages
Book Rating : 4.7/5 (82 download)
Download or read book Indian Double Taxation Agreements & Tax Laws 5Th / Ed. written by D P Mittal and published by . This book was released on 2008-09-01 with total page 3552 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Comprehensive and authentic Commentary on Indian Double Taxation Agreements with the help of decisions of International & Indian Courts as well as Authority for Advance Rulings * A comprehensive & critical study of UN Model Convention * Comparative and critical analysis of OECD Model Convention * Doing business with or in India, including e-business * Genesis and development of Treaty Models * Supremacy of a Tax Treaty over the domestic laws * Interpretation of a Tax Treaty * Classification of Income * Scope and purpose of a Tax Treaty * Taxes covered by a Treaty * Explaining definitions and expressions used in a tax treaty such as 'Resident', 'Permanent establishment', and others including 'Transfer pricing', 'Arm's length transactions', 'Treaty Shopping', etc. * Explaining expressions used in domestic tax laws but not defined in tax treaties such as Income (Real Income, Fictional Income, Substance over form). Total Income, Business, Profession, Computation of Income, etc. * Computation of income and distributive rules relating to income from Business, Shipping Business, Associates Enterprises, Capital Gains, Investment Income (dividends, interest, and royalties), Income from activities (personal and impersonal, pensions, directors' fee, entertainment, athletes, sports), Remuneration to students, etc. * Non-discrimination * Mutual agreement procedure for resolving disputes * Methods of eliminating Double Taxation, including Tax Sparing * Test of Double Taxation Agreements and Compendium of Relevant Circulars * Compendium of Rulings of Authority of Advance Rulings
Author : Joseph Isenbergh
Publisher : Thomson West
ISBN 13 :
Total Pages : 322 pages
Book Rating : 4.F/5 ( download)
Download or read book International Taxation written by Joseph Isenbergh and published by Thomson West. This book was released on 2005 with total page 322 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Taxation discusses international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. Divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.Summary of Contents" Part I: Basic Elements of International TaxationChapter1. U.S. Taxation in the International Setting2. Nationality and Residence for Taxation3. The Source of Income4. International Transfer Pricing" Part II: Inbound U.S. Taxation5. U.S. Taxation of Foreign Persons: Passive Income6. The Meaning of a U.S. "Trade or Business"7. "Effectively Connected" Income8. Gains from Sales of U.S. Real Property9. The Branch Profits Tax" Part III: Outbound U.S. Taxation10. Outbound Taxation in Overview11. The Foreign Tax Credit: Background and Overview12. The Foreign Tax Credit: Creditable Foreign Taxes13. The Credit Limitation of Section 90414. The Indirect Foreign Tax Credit15. Grand Overview of Dividends from Foreign Corporations16. Controlled Foreign Corporations: Subpart F17. Controlled Foreign Corporations: Section 124818. Passive Foreign Investment Companies (PFICs)19. International Corporate Reorganizations20. U.S. Citizens Abroad21. Income Tax Incentives for Exports" Part IV: Income Tax Treaties22. Income Tax Treaties in Overview23. Residence in Income Tax Treaties24. Business Profits - Permanent Establishments25. Compensation for Personal Services26. Interest, Dividends, Royalties, Rents, and Other Gains27. The Rise and Fall of Treaty Tax Shelters: Sandwiches, Conduits, and the Treasurys Response" Table of Cases" Index
