Lawsikho - Courses

Module Name : Introduction To International Taxation And Transfer Pricing

Chapter: Why should non-tax experts know about transfer pricing?

Chapter: When are principles of international taxation attracted?

Chapter: When does transfer pricing become applicable?

Chapter: Does international tax law apply to you if you do not have an office offshore?

Module Name : Legal Framework For International Taxation

Chapter: Sources of International Tax Law

Chapter: Domestic law provisions

Chapter: Double Taxation Avoidance Agreements and Structure

Chapter: Permanent Establishment (in Model Agreements and DTAAs)

Chapter: Capital Gains

Chapter: Royalty

Chapter: Fee for Technical Services

Chapter: Tax Information Exchange Provisions

Chapter: Tax Credit / Refund Provisions

Chapter: Model Tax Treaties and treaty interpretation of DTAAs under VCLT and OECD

Chapter: Business Connection under Income Tax Act

Chapter: International Tax Issues in Secondment Arrangements

Module Name : Guiding Concepts For Transfer Pricing

Chapter: Arms’ Length Pricing and methods

Chapter: Comparable uncontrolled price method (CUP)

Chapter: Resale Price Method

Chapter: Cost-Plus Method

Chapter: Transactional net Margin method(TNMM)

Chapter: Profit Split Method

Chapter: How to choose an appropriate method

Chapter: Role of an advanced pricing agreement

Chapter: Associated Enterprises

Chapter: Permanent Establishment

Chapter: Taxation of Foreign Companies_ PoEM Rules

Chapter: Safe Harbour Rules

Chapter: Place of Effective Management

Chapter: Sample Transfer Pricing Agreement

Chapter: International Tax Issues in Secondment Arrangements

Module Name : International Tax Planning

Chapter: International tax structuring for global businesses

Chapter: Case study of India - Mauritius DTAA

Chapter: How Foreign Tax Credit Works

Chapter: International Tax Structuring and Tax Havens

Chapter: Tax Structuring, Base Erosion and Profit Shifting (BEPS)

Chapter: Why the amended Mauritius India DTAA will not impact foreign investment

Chapter: General Anti-Avoidance Rule (GAAR)

Chapter: Do Commissionaire arrangements constitute a PE?

Module Name : Penalties & Dispute Resolution

Chapter: Penalties under Indian domestic law

Chapter: Tax avoidance and tax evasion

Chapter: General Anti-Avoidance Rule (GAAR) and Special Anti-Avoidance Rule FATCA

Chapter: Information exchange provisions

Chapter: International cooperation under DTAAs

Chapter: Tax Information Exchange Agreements (TIEAAs)

Chapter: Case study of Switzerland’s secrecy norms under DTAAs

Chapter: How to safeguard against future regulatory risks - Authority for Advanced Rulings (AAR)

Chapter: Settlement of disputes with tax authorities

Chapter: Transfer pricing disputes in offshore jurisdictions

Certificate Course in International Taxation and Transfer Pricing

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