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Double Taxation Avoidance Agreements (Multilateral Conventions and Foreign Collaborator Taxation)

Double Taxation Avoidance Agreements (Multilateral Conventions and Foreign Collaborator Taxation)

  • ₹995.00

In Stock
  • Author(s): R P Garg
  • Brand: Young Global Publications
  • Edition: Ed 2018 January
  • ISBN 13 9788188274840
  • Approx. Pages 585 + contents
  • Delivery Time Normally 7-9 working days

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Description
This ANU'S understanding is an attempt to bring in focus the basics of tax treaty law in simple language with reference to 2017 Multilateral Convention (MLI), taxation of non resident collaborators, the substantive provisions of law, rules, procedures and working of the treaties. This treatise would be a shorter but comprehensive practical guide as capsules to understand. It deals in detail with the grounds on which relief can be sought from the tax administration under the Income tax Act, 1961 and the DTAAs. It would be useful to both beginners as well as established ones in tax practice, to tax executives, and the taxpayers.
The introductory Chapter 1 contains general introduction to law of treaties narrates various statutory provisions in income tax law in India and the impact of treaties DTAAs and MLI on tax position of a taxpayer at a glance.
Chapter 2 depicts the Scope of the DTAAs with MLI effect within 5 sub chapters, persons covered, taxes with withholding tax specifics, interpretation of terms used in the DTAA, like residential status, permanent establishment, person as a tax entity and applicability of the domestic tax laws in India when a term is not defined in the DTAA
Chapter 3 provides the position of tax jurisdiction of the country of residence of the tax payer and the source state vis a vis characterisation on income from property, business with PE pendulum, use of equipment, know-how, and money, independent and dependent services, directors fee and remuneration, artist
sports persons, Government service, pensions and social security other income and capital taxation.
Chapter 4 details double taxation relief the tax, LOB, Non discrimination.
Chapter 5 has discussion on Assistance and regulations- Mutual assistance, exchange of information and mutual procedure Agreement and diplomatic exemptions.
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Contents
1.       Tax Treaty-An Introduction
2.       Scope of DTAA/Convention/Treaty
2.1     Persons Covered
2.2     Taxes Covered
2.3     Interpretation and Definitions
2.4     Resident
2.5     Permanent Establishment
3.       Scope of Income Tax and Jurisdiction
3.1     Taxation of Income
3.2     Business Profits
3.3     Shipping, Inland Waterways Transport and Air Transport
3.4     Associated Enterprises
3.5     Dividends
3.6     Interest
3.7     Royalties
3.8     Capital Gains
3.9     Independent Personal Services
3.10   Dependent Personal Services
3.11   Directors' Fees and Remuneration
3.12   Artistes and Sportspersons
3.13   Pensions and Social Security Payments
3.14   Government Service
3.15   Students
3.16   Other Income
3.17   Capital
4.       Double (Non) Taxation Avoidance
4.1     Limitation on Benefits
4.2     Double Taxation/Double Non Taxation
4.3     Non Discrimination
5.       Assistance & Regulations
5.1     Mutual Agreement Procedure (MAP)
5.2     Exchange of Information (EOI)
5.3     Mutual Assistance
5.4     Diplomatic Agents Immunity
5.       Assistance & Regulations
5.1     Mutual Agreement Procedure
5.2     Mutual Assistance
5.4     Diplomatic Agents Immunity
6.       Territorial Extension Entry & Termination
7.       Taxation of Non resident/Collaborators
Appendix
Appendix  1    OECD 2014
Appendix  2    UN MTC Convention 2011
Appendix  3    US Model 2016
Appendix  4    Multilateral Convention
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Author Details
SHRI R P GARG, an Advocate specialising in Direct tax laws having 47 experience, as a Chartered Accountant, as an advocate of High Courts and Supreme Court and as a member of Income Tax Appellate Tribunal for a period of over 23 years conducting tax second appeals, and retired as the Senior Vice President thereof. Academically, he is a commerce graduate, a Fellow member of the Institute of Chartered Accountants of India and has a Master degree in law from Delhi University, India.
He has been a continuous source of contributing papers in seminars and tax journals on International and Indian tax laws. He is also a senior tax consultant to internationally reputed firms dealing in tax and treaty matters. He has been the co-authors of books on international law, Income tax, Limitation & Arbitration and Gift tax laws, law of tax treaty, Practice and procedure before ITAT.
MRS SUNITA GARG is an advocate having 30 years standing. She is specialising expert in civil and tax litigation in various High Courts in India. Academically she is a Commerce graduate and a Bachelor of law. She has been contributing papers in seminars and tax journals on International and Indian tax laws.
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