Lawsikho

Introduction

All waitlist participants shall be informed about the next enrollment date

Global corporations such as Apple, Google, Amazon, and Facebook save billions in taxes due to effective tax structuring and tax planning. To mitigate tax liability, Google uses a complicated legal structure that has saved it $47.4 billion. Multinationals that have subsidiaries in various countries, including markets where they benefit from lax tax laws let them save an estimated $90 billion in federal income taxes each year. Further, 60% of transactions across the world are between related party entities and involve transfer pricing.

In this context, there is an ever-expanding opportunity for professionals to acquire highly specialized skills in international tax advisory and litigation. Further, this book will also provide you with an understanding of complex issues involved in this spectrum and how can you advise companies to mitigate tax liabilities?

Who should take this course?

CA
CS
Lawyers
Management consultants
Business owner
Entrepreneurs

What is the career potential after doing this course?

Understanding of international taxation and transfer pricing can be useful in the following ways in one's professional/academic career:
Create strategies for the structuring of cross-border transactions to reduce your overall tax bill. Expand your practice in the International Taxation domain. Advise businesses on how related-party entities should carry business in accordance with the transfer pricing rules. Learn how to negotiate and draft advance pricing agreements.
How to advise someone in structuring the global operations of a business to save tax?
How to optimize tax liability for cross-border transactions?
How to use tax havens for high-value business transactions?
How can you save multinational companies from overlapping tax regimes of multiple jurisdictions?
How should you deal with tax authorities in case of international tax disputes?
What planning measures can you adopt in case of complex international transactions to minimize tax uncertainty?
How to apply advanced tax planning strategies to a unique cross-border structured financial product.
How tax haven countries can help you mitigate your tax liability
How to interpret tax-treaties
How you can resolve disputes effectively in the field of international taxation.
How to identify and resolve tax controversy issues at the time of structuring a transaction.
How you can claim benefits under DTAA.

Potential employers

Law firms
In-house legal teams of companies
Central and state governments
PSUs
Independent litigators

Relevant Industries

Banking

Legal

Finance

Insurance

Technology

GOVERNMENT

What is unique about this course?

The course is not limited to a provision-by-provision study of some statutes and associated case laws alone
The course trains you on different kinds of actual work that is required to be performed by lawyers and other professionals. After finishing the course, you will know as much practical knowledge as a lawyer working at a big law firm will know after a year or two of experience
It is not a mere theoretical study, but all the lessons are based on the practical application of the topics dealt with in the course
You will get personal attention and coaching from the trainers, and any doubt regarding a topic shall be addressed within 48 hours
You will be given an opportunity to work on two writing assignments during the term of the course that shall be published either on iPleaders blog or any other industry publications if it meets our specifications
In the span of the course, you shall be accessed over 3 subjective-based exercises relating to the course topics that shall help you to understand the practical aspects of the subject
The course is tough and intensive, you will not be awarded the certificate unless you complete all the 3 subjective exercises and 2 writing assignments, as mentioned above.

Syllabus

Introduction To International Taxation And Transfer Pricing

Why should non-tax experts know about transfer pricing? When are principles of international taxation attracted? When does transfer pricing become applicable? Does international tax law 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

Guiding Concepts For 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

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 Tax Structuring, Base Erosion and Profit Shifting (BEPS) Why the amended Mauritius India DTAA will not impact foreign investment General Anti-Avoidance Rule (GAAR) Do Commissionaire arrangements constitute a PE?

Penalties & 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) Case study of Switzerland’s secrecy norms under DTAAs How to safeguard against future regulatory risks - Authority for Advanced Rulings (AAR) Settlement of disputes with tax authorities Transfer pricing disputes in offshore jurisdictions