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Module Name : 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?

Module Name : 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

Module Name : 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

Module Name : 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?

Module Name : 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

Certificate Course in International Taxation and Transfer Pricing

Enrolments for this course have been closed

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