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Basic Concepts of International Taxation

Basic Concepts of International Taxation

  • ₹3,300.00

  • ₹3,135.00

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  • Author(s): D.C.Agrawal
  • Publisher: Taxmann
  • Edition: Ed 2016
  • ISBN 13 9789350719688
  • Approx. Pages 1516 + Contents
  • Format Hardbound
  • Approx. Product Size 24 x 16 cms
  • Delivery Time Normally 7-9 working days
  • Shipping Charge Extra (see Shopping Cart)

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Description 

The Present Publication, authored by D.C. Agarwal, is the latest edition, with the following noteworthy features:
This book’s objective is as follows:
1. Provide a general idea about various Articles in the OECD Model Convention, based on OECD commentary 
     on Model Convention  and the Courts/Tribunal decisions
Explains in detail, various concepts used in OCED Model Convention
Provides comprehensive materials on these subjects for reference and guidance
2. In line with the book’s objectives, it enables the reader for the following:
* Understanding various Articles provided in the OECD Model Convention
*  Enabling the reader to understand various concepts used in International Taxation and apply them with greater ease and comfort
* Knowing various judgements, rendered by Courts & ITAT, on the topics covered in this book
* Equipping the reader for better and effective tax planning, tax assessment and defense before judicial authorities.

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Contents

Chapter 1. Introduction
Chapter 2. Persons Covered (Article 1 of the OECD MC)
Chapter 3. Taxes Covered (Article 2 of the OECD MC)
Chapter 4. General Definitions (Article 3 of the OECD MC)
Chapter 5. Subject to Tax (Relating to Article 1 of OECD MC)
Chapter 6. Source vs. Residence (Article 4 of OECD MC)
Chapter 7. Place of Effective Management (Relating to Article 4 of OECD MC)
Chapter 8. Permanent Establishment (Article 5 of OECD MC)
Chapter 9. Income from Immovable Property (Article 6 of OECD MC)
Chapter 10. Business Profits (Article 7 of OECD MC)
Chapter 11. Force of Attraction (Relating to Article 7 of OECD MC)
Chapter 12. Income from Shipping and Aircraft Business (Article 8 of OECD MC)
Chapter 13. Associated Enterprises (Article 9 of OECD MC)
Chapter 14. Transfer Pricing (Relating to Article 9 of OECD MC)
Chapter 15. Dividend (Article 10 of OECD MC)
Chapter 16. Taxation of Interest (Article 11 of OECD MC)
Chapter 17. Royalty (Article 12 of OECD MC)
Chapter 18. Fees for Technical Services (Relating to Article 12 of OECD MC)
Chapter 19. “Make Available” (Relating to “Fee for Technical Services”)
Chapter 20. “May Be Taxed” and “May Also Be Taxed”
Chapter 21. Capital Gains (Article 13 of OECD MC)
Chapter 22. Independent Personal Services (Articles 14 of OECD MC)(Deleted)
Chapter 23. Income from Employment (Article 15 of OECD MC)
Chapter 24. Director’s Fees (Article 16 of OECD MC)
Chapter 25. Entertainers and Sportspersons (Article 17 of OECD MC)
Chapter 26. Pensions (Article 18 of OECD MC)
Chapter 27. Government Service (Article 19 of OECD MC)
Chapter 28. Other Income (Article 21 of OECD MC)
Chapter 29. Students (Article 20 of OECD MC)
Chapter 30. Capital (Article 22 of OECD MC)
Chapter 31. Foreign Tax Credit (Article 23 of OECD MC)
Chapter 32. Non-Discrimination (Article 24 of OECD MC)
Chapter 33. Treaty Shopping
Chapter 34. Tax Sparing
Chapter 35. Tax Evasion and Tax Avoidance
Chapter 36. Double Taxation/Double Non-Taxation
Chapter 37. Interpretation of Statutes and Tax Treaties
Chapter 38. Withholding Tax
Chapter 39. Limitation of Benefit Rule
Chapter 40. Tax Havens
Chapter 41. Treaty Override
Chapter 42. Thin Capitalization
Chapter 43. Beneficial Ownership
Chapter 44. Mutual Agreement Procedure (Article 25 of OECD MC)
Chapter 45. Exchange of Information (Article 26 of OECD MC)
Chapter 46. Assistance in the Collection of Taxes (Article 27 of OECD MC)
Chapter 47. Members of Diplomatic Mission and Consular Posts (Article 28 of OECD MC)
Chapter 48. Territorial Extension (Article 29 of OECD MC)
Chapter 49. Entry into Force (Article 30 of OECD MC)
Chapter 50. Termination (Article 31 of OECD MC)

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Author Details
D.C. Agrawal, Advocate, has a vast experience in the field of taxation. He served in Income Tax Department as an IRS officer for about 30 years. Thereafter in 2005, he was elevated to Income Tax Appellate Tribunal where he served as Accountant Member till his superannuation in July, 2011. In Income Tax Department, he served in various capacities, from Assessing Officer, Investigating Officer and Departmental Representative before Income Tax Appellate Tribunal and Income Tax Settlement Commission. During his tenure as Investigating Officer in Delhi, he has been associated with some high profile cases.

Apart from being IRS, he holds Master’s Degree in Science. He is Law Graduate and is also a qualified Cost and Works Accountant. As an Accountant Member of Income Tax Appellate Tribunal, he has authored several landmark Judgments which have been published in leading Tax journals. He has also authored about 200+ Articles, particularly carrying analysis of judgments rendered by Hon’ble High Court and Income Tax Appellate Tribunal. These Articles are published in leading journals such as Corporate Professional Today.

Currently, he is practising as an Advocate and Consultant and also appearing before Income Tax Appellate Tribunal and Income Tax Settlement Commission. He has represented in several important matters involving issues relating to domestic taxes, Transfer Pricing and International Taxation.

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