Our Comprehensive International Taxation Course on Article by Article , analysis of Tax Treaty helps students to understand all aspects of International Tax – The International Tax Course has students from 30+ countries. This International Tax Course helps you learn, how to interpret various Articles in Tax Treaty
Language : English
Video Duration: 20.45 Hours.
Along with : E-Book (538 pages)
Online – Rs 2800 ( 6 Months Validity )
This Course is meant for learners who want to learn, explore and enhance their knowledge on the complex area of International Tax.
For any query Call – 9667222008
Course Curriculum
Course - Introduction
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Article 1- Person covered
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- 1. Need for a tax treaty in International Trade- Part 2 (2:51)
- 1B. Need for a tax treaty in International Trade
- 2. What is a Tax Treaty (3:41)
- 3. Various Models of Tax Treaties- UN, OECD and US Model (2:55)
- 4. What are the key considerations for the Contracting Countries at the time of ent (2:19)
- 5. Contents of a Tax Treaty- Various Clauses (3:38)
- 6. Consideration of tax treaties- Not only tax (4:13)
- 7. Provision of Income Tax Act, 1961 vs. Tax Treaty - Section 90(2) (5:39)
- 8. General provisions of Tax Treaty (5:35)
- 9. Subsequent amendment of it act, 1961 (3:31)
- 10. Impact of subsequent amendment of Income Tax Act, 1961 on earlier tax Treaties (1:43)
- 11. Impact of subsequent amendment of Income Tax Act, 1961 on earlier tax Treaties (3:43)
- 12. Withholding tax- Governing rules vis a vis Tax Treaties (4:32)
- 13. Interpretation of Treaties- Liberal or Strict (1:54)
- 14. Tools for Interpreting Treaties - Protocol, Technical Expalnations, Commentaries (3:10)
- 15. Vienna Convention on Law of Treaties as an aid to Treaty Interpretation (2:53)
- 16. Purpose of Model commentaries - OECD and UN Model (2:50)
- 17. Purpose of Model commentaries & India's stand on OECD Commentary (4:14)
- 19. India_s stand on UN Model Convention and Commentary (1:48)
- 20. Other aids for interpreting treaties (2:58)
- 21. Different views by two contracting states (3:23)
- 22. Interpretation of "words" used in Treaty - Treaty definition vs Income Tax Act, (2:09)
Article 2- Taxes Covered
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- 1. What are the taxes which are covered in Tax Treaty under (6:57)
- 2. Understanding draft Article 2 of India- Netherlands and India- USA Treaty (9:24)
- 3. Key Features and Coverage of Article 2 relating to taxes (2:36)
- 4. What is regarded as Taxes on income and on capital (7:47)
- 5. Key feature of article 2(2) of India USA Treaty (0:55)
- 6. Article 2(3) - Specific countrywide taxes which are covered (4:29)
Article 4- Residence
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- 1. Concept of Residence and its importance in Tax Treaties (7:28)
- 2. Who are Resident - Article 4(1) (6:43)
- 3. Reasons of being liable to tax in a Country, which should be satisfied to become a resident (1:55)
- 4. Sovereign Funds and Collective Investment Vehicles - Tax residency (4:44)
- 5. Meaning of the Term Resident and Person (2:38)
- 6. Interplay of Article 4(1) and Income Tax Act 1961 (2:07)
- 7. Liable to tax therein - Person who are not taxable (15:10)
- 8. Proof of being a resident of a Contracting State (3:14)
- 9. Article 4(2) - Tie breaker Rule in case of an individual (6:34)
- 10. Permanent Home, centre of Vital Interest, Habitual abode and Nationality (6:26)
- 11. Article – 4(3) – tie breaker rule – person other than an individual (7:37)
Article 5 - Permanent Establishment
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- 1. Understanding the Basics of Permanent Establishment and Business connection and there relevance (5:02)
- 2. Concept of Business Connection and Permanent Establishment under the Income Tax (7:57)
- 3. Characteristics of Permanent Establishment and key components of the Presentation (5:47)
- 4. Scheme of Article 5 - What all is covered (3:48)
- 5. Article 5(1) - Fixed Place of Business (14:25)
- 6. Meaning of "Business carried on by the PE" and certain Case studies on PE (5:31)
- 7. Article 5(2) - Inclusion in PE - Construction and Installation PE (16:37)
- 8. Service Permanent Establishment (6:40)
- 9. Auxilliary of Preparatory Activities (10:15)
- 10. Agency Permanent Establishment - Dependent Agent (14:07)
- 11. Habitually securing orders in the Source State for NR (4:05)
- 12. Article 5(5) Independent Agent (8:30)
- 12B (2:01)
Article 6- Income from Immovable Property
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- 1. What is taxable under Article 6 - Immovable Property (3:17)
- 2. Right of India and Treaty partner to tax income from Immovable Property (4:05)
- 3. KEY ISSUES IN ARTICLE 6(1) - location OF property, meaning of income (4:08)
- 4. Meaning of immovable property and Property used for providing Independent Personal Services (4:04)
- 5. Computation of income from immovable property (0:56)
Article 7- Taxation of Business Profits
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- 1. Article 7 Business Profits - Steps to be followed for ascertaining applicability of Article 7 (9:04)
- 1A. Structure of various clauses covered under Article 7 of the India USA Treaty (2:15)
- 2. Article 7(1) - Right of the Source State to ta Business Profits and which profits are taxable (8:26)
- 3. Turnkey contracts – activities in _ outside india (5:37)
- 4. Computing profits attributable to a PE under Article 7(2) (15:50)
- 5. ARTICLE 7(3) – INDIA USA TREATY – expenses allowed as a deduction and cross charges etc (12:19)
- 6. Mere purchase of goods by PE and attribution of income - Article 7(4 (3:11)
- 7. Profits from assets and activities of the PE - Article 7(5) (3:07)
- 8. ARTICLE 7(6) – INDIA USA TREATY – items dealt with in other article (2:25)
- 9. Meaning of business profits under Article 7 (7) (1:51)
- 10. Rule 10 of the IT Rules - Allocation of profits to NR (3:27)
Article 8 - Taxation of Shipping and Air Transport Profits
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- 1. Article 8 - Shipping or Aircrafts - Right to tax and condition for taxation under Article 8 (10:03)
- 2. Understanding impact of Place of Effective Management in Taxation of Shipping and Airline Profits (3:32)
- 3. Conditions for applicability of Article 8 and exclusions thereon (2:55)
- 4. Engineering Services to other airlines - whether covered under Article 8 of India UK Treaty (2:06)
- 5. Article 8(2) – Meaning of Profits from operation of ships and aircrafts, Meaning of Inland Waterways (10:10)
- 6. Article 8(3) – India-us tax treaty Profit from containers (1:43)
- 7. Article 8(4) – profit from participation in a pool India-us tax treaty (2:14)
- 8. Article 8(5) – interest on funds connected with operations - India-us tax treaty (3:19)
- 9. Activities covered and excluded by Article 8 (2:31)
Article 9 - Associated Enterprise
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- 1. What are Associated Enterprise (3:17)
- 2. Components of associated enterprise (2:19)
- 3. Associated Enterprise - Article 9 of India - Usa treaty (9:46)
- 4. Meaning of Control (1:09)
- 5. Case Study on Excessive expenditure disallowance under Article 9(1) (2:18)
- 6. Article 9 - Coorelative adjustments alongwith case studies and example (6:09)
- 7. Concept of Secondary Adjustment (2:43)
- 8. Associated Enterprises as per IT Act - Ownership, Loan, Guarantee of total borrowings (7:06)
- 9. AE - Part 2 (4:58)
- 10. AE Part 3 (4:15)
Article 10 - Dividend
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- 1. Article 10 Dividend - Key aspects to be covered (4:57)
- 2. Meaning of Dividend (2:39)
- 3. Right to tax dividend, what is covered as dividend and meaning of dividend paid (9:39)
- 4. Right of Source State to tax - Part 1 - Conditions and examples on beneficial ownership (8:16)
- 5. Beneficial ownership and right to opt for provision of Income Tax Act, 1961 (6:21)
- 6. Meaning of Dividend - Article 10(3) (6:20)
- 7. PE or Fixed base and taxation of dividend - Article 10(4) (3:36)
- 8. Right to tax dividend declared by foreign company (5:07)
Article 11 - Taxation of Interest
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- 1. Article 11 - Taxation of Interest and Various issues arising therein (8:20)
- 2. Article 11 (1) – Right of state of residence to tax interest (4:47)
- 3. Article 11(2) - Right of Source State to tax interest (5:55)
- 4. Beneficial ownership test and examples on conduit companies for interest income (5:50)
- 5. exemption in source state for certain interest (4:22)
- 6. Article 11(4) - What is covered as Interest (7:47)
- 7. Taxation of interest where the NR has a PE in India (6:35)
- 8. When shall interest be treated as Arising in India (5:09)
- 9. Taxation of excess interest paid to related party (4:49)
Article 12 - Royalty and Fee for Technical Services
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- 1. Introduction to Royalty and Fee for Technical Services (2:00)
- 2. What topics are covered in this Course of Royalty and Fee for Technical Services (1:16)
- 3. Key Learning objectives of the Presentation (1) (7:26)
- 4. Royalty & FTS – Scenario of Taxability in India and Rights of India and Other Contracting State (7:11)
- 5. Beneficial Provision of the Treaty or Act - Which one are applicable ? (3:38)
- 6. Proof of Tax Residence of Non resident – Section 90(4)&90(5) (8:32)
- 7. Approach to ascertain Tax implications on Royalty _ FTS (0:57)
- 8. Approach to ascertain Tax implications on Royalty _ FTS and ascertaining withholding tax rates (9:34)
- 9. Section 9(1) - Charging provisions for taxation of Royalty (14:14)
- 10. Imparting of any information Classified as Royalty (5:43)
- 11. Royalty and FTS - When do they Arise in India (8:06)
- 12. Royalty for Transfer of all or any rights (8:03)
- 13. Royalty under Income Tax Act – Types of payments covered (11:26)
- 14. Scope of Total Income and Royalty & FTS (3:03)
- 15. Tax deductibility of Royalty in hands of Payer (3:01)
- 16. Article 12 (1) – India USA Treaty – Right of the state of residence to tax royalty (7:00)
- 17. Right to opt for tax rate under the Act for one Contract and under the Treaty for another (7:48)
- 18. Article 12(3) - Definition of Royalties (9:46)
- 19. Whether both Dry and Wet Lease amount to use of Equipment (1) (1:47)
- 20. Lease and Sale of Ship - Which one is Royalty (1:48)
- 21. Whether payment for use Copyright of literary, artistic or scientific work amounts to Royalty (2:49)
- 22. Royalty definition - Comparison of Act, OECD _ UN Model (4:01)
- 21. Article 12 (4) – India USA Treaty – fee for included services (7:23)
- 22. Concept of Make available and development and transfer of technical plans and designs (3:46)
- 23. Article 12 (5) – India USA Treaty – FIS exclusion (4:58)
- 24. Article 12(6) - Royalty and FIS effectively connected to a PE (13:37)
- 25. ARTICLE 12(6) - Where do royalty or FTS arise (8:08)
- 26. Article 12(8) - Excess Payments to related Enterprise (5:09)
- 27. Most Favored Nation Clause (MFN Clause) (3:53)
Article 13 - Capital Gains
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- 1. Introduction to Article 13 Capital Gains (4:03)
- 2. Objectives of Presentation on Capital Gains (8:04)
- 3. Capital Assets covered under Article 13 (4:31)
- 4. Which Country has the right to tax Capital Gains ? (6:02)
- 5. Approach to be followed to ascertain Taxation of Capital gains (3:54)
- 6. Meaning of term "Alienation" (4:52)
- 7. Existence of PE of Transferor on Capital Gains arising from Alienation of Asset (5:07)
- 8. Minimum Alternate Tax (MAT) on Foreign companies deriving capital gains (4:16)
- 9. Capital gains on transfer of immovable property referred to in Article 13 (7:50)
- 10. Case Study on Sale of shares of Indian company owning immovable property and transfer of tenancy rights (2:05)
- 11. Article 13(2) - Transfer of Movable property forming part of the business property of the PE (9:07)
- 12. Article 13(3) - India – Netherlands – ships or aircraft operating in international traffic (6:28)
- 12B. Capital gains on transfer of ship (2:27)
- 13. Article 13(4) - Transfer of shares of a real estate company (8:41)
- 14. Article 13(5) - Alienation of any other property (3:43)
- 15. Factors not considered to be relevant while applying article 13(5) (6:39)
- 16. Capital gains on transfer of ship (2:27)
Article -14 - Independent Personal Services
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- 1. Introduction to Article 14 - Independent Personnel Services and Interplay vis a vis Article 7 and 15 (5:59)
- 2. Right of State of Residence to tax income from Independent Personal Services
- 3. Applicability of Article 14 to non individuals (2:33)
- 4. Payments to Foreign Company for Artiste Services (1:50)
- 5. Inclusions and exclusions from Article 14 (4:05)
- 6. What is a Fixed Base and its examples (4:18)
Article - 15 - Dependent Personal Services
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- 1. Introduction to Article 15 and difference with Independent Personal Services (3:53)
- 2. Provision of the Income Tax Act for Taxation of Salaries paid to Non Resident (5:49)
- 3. Right of the contracting states to tax employment income (8:57)
- 4. Taxation of Stock Option (9:42)
- 5. Short Stay exemption - DPS income taxable only in State of Residence (10:28)
- 6. Employment exercised aboard a ship or aircraft operating in International Traffic (1:39)
Article - 17 - Artistes and Sportsperson
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- 1. What is covered by Article 17 (2:01)
- 2. Scope of taxation of an Artiste or Sportsperson (4:49)
- 3. Crtierion for services for Article 17 (2:35)
- 4. Who are covered as a Sportsperson or Entertainer (4:43)
- 5. Meaning of "Personal activities" for Article 17 (1:57)
- 6. Income covered under Article 17 and Allocation of Consolidated Income (3:27)
- 7. Certain issues in connection with Article 17 (4:42)
- 8. Income of Artiste accruing to a third person (6:02)
- 9. Triangular Cases - Application of correct Treaty (2:23)
- 10. Computation of Income for Article 17 in Source State - Mechanism (1:48)
- 11. Commission to Non resident for arraning artiste - Whether taxable under Article 17 (2:12)
Article-18 Pension and other remunearation
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- 1. Scope of Article 18 - Pension and other similar remuneration (5:50)
- 2. Type of Pensions covered (1:04)
- 3. What is covered under Pension and other Similar Remuneration (1:54)
- 4. Pension Paid as Consideration for Past employment (2:10)
- 5. Non periodical payments for past employment - Article 18(2) (2:49)
- 6. Pension paid out of social security system of the State and menaing of annuity (3:57)
Article 19 - Government services
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- 1. What income is covered under Article 19 (7:40)
- 2. What is meant by Government, State or local authority for purpose of Article 19 (5:06)
- 3. Right to tax with Foreign State if services rendered there, recipient is a resident (3:17)
- 4. Taxation of Pension paid by Government _ Remuneration and Pension paid by Government for Business carried on by it (5:04)
Article - 20 - Students
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- 1. Who all are covered under Article 20 - Taxation of Students (3:35)
- 2. Conditions to claim exemption for taxation of students under Article 20 (5:31)
- 3. Resident for the purpose of Article 20 (3:57)
- 4. Income of students from Sources Outside the Host State (1:40)
- 5. Taxation & Purpose of visit of student (3:10)
Article 21 - Other Income
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- 1. Applicability of Article 21 - Other Income (4:03)
- 2. Key characteristics of Other Income Article 21 (5:00)
- 3. Meaning and coverage of "Dealt with" to ascertain if income is taxable (4:00)
- 4. Taxability of income as other income when relevant clause absent - royalty (2:02)
- 5. Taxation of excess royalty payments to related party (3:27)
- 6. Taxation of other income attributable to the PE of the Non resident in India (3:52)
- 7. Right of India to tax Other income which arise in India (3:10)
Article 23 - Elimination of Double Taxation
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- 1. Introduction to Article 23 - What is covered (4:01)
- 2. Applicability of article 23 - Losses in State of Residence and taxability (2:56)
- 3. Types of Relief from Double Taxation - Unilateral an Bilateral Relief (4:35)
- 4. Underlying credit and Tax Sparing (7:21)
- 5. Methods of Tax Credit - Exemption and Credit Method (5:50)
- 6. Article 25(1) of the India USA Treaty - Credit against the US taxes (7:28)
- 7. Article 25(2) of the India USA Treaty - Credit against the Indian taxes (7:11)
- 8. Article 25 (3) – India USA Treaty – Where does income arise (6:32)
- 9. Key controversies issues in claiming Foreign Tax credit (6:04)
- 10. How to claim credit for the taxes paid in Foreign country and Triangular Treaty cases (1:16)
Article - 24 - Non-Discrimination
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- Introduction_to_Non_Discrimination_and_Types_of_discrimination_under_Treaty (8:58)
- Article_24(1)_-_Discrimination_based_on_Nationality (7:58)
- Discrimination_to_a_PE (7:29)
- Deduction_of_expenses_to_an_Indian_Company_-_Non_Discrimination (5:00)
- Article_26_(4)_-_Discrimination_based_on_Indian_or_Foreign_ownership (4:14)
- Article_26(5)_-_PE_tax_or_Limitation_on_deduction_of_expenses_under_Article_7(3) (1:03)
- Examples_of_Non_Discrimination (1:24)
Article 25 - Mutual Agreement Procedure
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- What_is_Mutual_Agreement_Procedure_(MAP)_and_its_applicability_in_the_Treaty (7:01)
- Implementation_of_MAP_under_Indian_domestic_laws (5:43)
- Article_27(2)_and_Article_27(3) (7:15)
- Developing_appropriate_Bilateral_and_Unilateral_procedure_for_making_MAP_work (6:12)
- Arbitration_clause_in_Treaty_under_MAP (2:55)
- Key_issues_and_challenges_for_MAP_and_following_application_in_subsequent_years (4:05)
Article 26 - Exchange of Information
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- Article_26_-_Exchange_of_Information_-_Introduction_and_Obligation_to_exchange (8:09)
- Key_Characterstics_of_exchange_of_information (2:47)
- Article_28_(1)_-_Use_and_Secrecy_of_information_obtained_under_EOI (7:49)
- Article_28_(2)_-_Frequency_of_exchange_of_information_by_Contracting_States (3:21)
- Article_28(3)_-_No_obligation_of_requested_state_to_provide_information (4:36)
- Obligation_to_provide_information_requested_for_Requested_State (2:24)
- Article_28_(5)_-_Taxes_covered_under_Article_26 (1:18)
- Decline_banking_-_ownership_information_under_certain_circumstances_for_exchange (1:52)
Article 27 - Assisstance in Collection of taxes
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- Background_of_quotAssistance_in_Collection_of_Taxesquot (2:02)
- Applicability_of_Article_on_Assisstance_in_Collection_of_Taxes (2:24)
- Revenue_claim_ceases_to_exist_-_Article_28(8) (2:41)
- Article_27(3)_-_Tax_to_be_collected_as_if_it_were_own_tax_of_other_Contracting (4:39)
- Interim_Measures_of_conservancy_for_collection_of_Revenue_claim (4:11)
- Priority_of_revenue_claim_India_Poland_Treaty_-_Article_28(6) (3:07)
- Proceedings_before_courts_-_Article_28(7) (2:06)
- Revenue_claims_that_a_Treaty_partner_shall_Assisst_in_Collection (4:45)
- Non_obligation_of_other_Contracting_State_to_recover_revenue_claims (2:01)
Article - 28 - Diplomatic Mission
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Article - 29 - Entry into Force
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Article 30 - Termination
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CA Arinjay Jain
I am an expert in International Taxation and M&A tax structuring wherein I have worked with KPMG as a Director in Indian practice helping large number of MNC, as well as domestic companies in the area of Inbound Investments, Outbound acquisition, cross border tax structuring, amalgamation, demerger, business sale amongst others. I have been a visiting faculty and have taught over 1500 professional students, until date taught over 20000 students through online effort to promote philanthropy in basic education.