International Tax Course (DTAA)

Comprehensive Course on Article by Article analysis of Tax Treaty to understand all aspects of International Tax

Created byArinjay Kumar Jain

Last updated 10/2024

English

What you'll learn

Gain knowledge on Taxation of Multinational Corporations in Source and Residence State
Learn taxation of Permanent Establishment, Fee for Technical Services, Capital Gains, Dependent Personal Services
Learn how system of credit of taxes paid in Source country can be obtained in State of Residence
Learn about taxation of Income from immovable property, Shipping and Inland waterways and other income not covered under other Article

Course content

26 sections • 286 lectures • 15h 3m total length

OECD - Article 1 Person Covered10:57
Introduction and Basic Concepts of Tax Treaty11:21
What is Tax Treaty and Various Tax Treaty Models6:46
Various Treaty Model - OECD, UN and US Model2:50
Objective of tax treaty8:01
Content and General Provision applicable to Tax Treaty7:25
Principle and Approach to Interpret tax treaty8:22
Tools to interpret Tax treaty11:36
Purpose of Model Tax Commentaries1:54
Different views on Taxation of Two contracting States2:08

Overview of Concept of "Residence"3:49
Importance of Concept of Residence in Tax Treaties3:06
Structure of Article – Resident1:54
Article – 4(1) of OECD Model – Who is Resident ?6:33
Categories of Resident1:24
Sovereign Wealth funds - Residence and Exemption from Tax2:26
Who is a “Person” under Tax Treaty ?1:36
Concept of “Liable to tax therein”3:00
Taxation of Partnership Firms - Are they Liable to tax2:01
Taxation of Charitable Trusts – Are they "Liable to tax"2:35
Permanent home -What constitutes Permanent Home to determine2:04
Centre of vital interest - Importance in Determination of Residence1:51
Habitual abode - When does it decided residence1:26
Nationality - When does it decide residence0:36
Mutual Agreement - Determination of Residence by Competent0:30
Article–4(3) of OECD Model-Tie breaker other than an Individual4:19
When would a Company can be taxed in two state ?2:09
Place of Effective Management Concept1:12

Overview of Article 5 - Permanent Establishment7:13
When can a PE arise in Source State-Office,Site or an Agent?4:59
How a Foreign Company can operate in Source State2:52
Article 5 of the OECD Model - Clauses3:59
PE - Other Important Aspects2:15
Article 5(1) – When does a Fixed Place PE arise under DTAA ?4:31
Key Characteristics of Fixed Place PE2:51
Leased Immovable Property and PE1:54
Place of Business – Examples3:36
Article 5 (2) – Specific Places included in Fixed Place PE5:39
Article5(3)Building Site,Construction or Installaton Project0:20
Construction PE - When does it arise ?1:30
Key Charctersticts of Construction PE0:55
Activities Resulting in Construction PE1:18
Installation PE – Activities Resulting in Installation PE0:26
12 Month Test–Aspects,Computation and Anti Abuse Provision11:00
Construction PE – Connected Activities2:33
Case Study – Fiscally Transparent Partnership2:29
Article 5(4)-Specific Activities Exempted from Constituting8:55
Criterion of Auxilliary or Preparatory3:10
Article 5(4)(a) - Facilities for Storage etc3:11
Article5(4)(b)-Maintenance of a stock of goods or merchandis1:31
Article 5(4)(c) - Maintenance of goods - processing1:12
Article 5(4)(d) - Purchasing Goods: Merchandise1:34
Article 5(4)(d) – Collecting Information for the Enterprise1:41
Places constituting preparatory work activities0:34
Article 5 (4.1) – Office constitutitng Closely related Co PE3:16
Article 5(5)- Dependent Agent1:30
Article 5(5) – Dependent Agent PE4:10
Dependent Agent PE - Key Characterstics2:30
Role of Agent in the Contract0:53
Key Characterstics of the dependent agent PE1:50
Case study – Conclusion of Contract1:37
Article 5 (6)- Independent Agent0:48
Article 5 (6)- Independent Agent not constituting a PE2:17
Key Criterion of an Independent Agent3:53
Article 5(7) - Subsidiary Permanent Establishment2:11
Case Study - Holding Subsidiary Relationship1:10
Article 5 (8) - Related Enterprise3:15

Income From Immovable Property-Key aspect and income cover3:52
Right Of Source State To Tax Income From Immovable Property5:10
Article 6(2) – Meaning Of Immovable Property3:33
Article 6(3) – Nature Of Income Covered 1:46
Article 6(4) – Immovable Property Of Enterprise1:31
Method of Computation Of Income In Source State1:15
Case Studies (1-3) on Article 6–Income From Letting And Subletting4:32

Overview of Article 7 Business Profits2:46
Relevance of Article 7 - Business Profits5:12
Structure of Article 7 - Business Profits3:54
Article 7(1) - Taxing Rights of Contracting State2:32
Characterstics of Article 7(1)1:40
PE Should be in Source State1:10
What is Taxable under Article 71:09
Article 7(2) - Determination of Profits of a PE6:40
Characterstics of Article 7(2)1:23
Basis of Allocating Profits1:13
How to Assertain Profits of a PE2:47
Deduction of Expenses - Rules violating Treaty?3:07
Article 7(3) - Deduction and Expenses5:36
Adjustment By State of Residence or State of Source0:20
Article 7(4) - Income Dealt with in other Article of Treaty1:11

International Shipping And International Air Transport4:07
Exclusive Right of State of Residence To Tax Profits3:21
Meaning Of “International Traffic” – Article 3(1) ( e)2:36
Alternative - Tax based on Place Of Effective Management4:23
Specific Income which are Taxable Under Article 86:55
What is Inland Waterways Transport and its relevance for 82:05
Permanent Establishment impact on Article 83:38
Profits From Pool, Joint Business Agreements and international2:21

Overview, Meaning and Tax aspect of Dividend5:32
Article 10(1) - Right of State of residence to Tax Dividend5:03
What is included within the meaning of Dividend ?2:08
What is excluded from the meaning of Dividend ?2:00
Article 10(2) - Right of Source State to Tax Dividend5:34
Beneficial ownership of Dividend - Meaning and case study3:10
Third Party Beneficial Owners of Dividend1:01
Beneficial ownership and Test of beneficial ownership6:16
Article 10(3) - Meaning of Dividend7:43
Taxation of Dividend Connected to PE or Fixed base3:12
Right to tax dividend declared by Foreign Co. From income4:20

Article 11 - Interest - Overview of Article 114:52
Learning Aspects of Article 11 - Interest4:24
Interest taxation - Important Issues4:02
Article 11 (1) – Right of State of Residence to Tax Interest6:10
Case Study - 1 - Interest Taxed on Payment Basis3:02
Case Study 2 – Interest From Third State Person1:07
Case Study 3 – Interest Attributable to PE in Third State1:15
Deduction of interest based on Residence of Recipient of Int4:51
Article 11 (2) - Right of Source State to Tax Interest7:16
Who is beneficial owner of interest ?3:01
Case study – Third State beneficial owner of interest1:40
Third Party Beneficial Ownership - Examples and Cases2:32
Disadvantage of Gross Taxation – Example - Banks2:30
Case Study – Gross WHT and impact on International Trade0:56
Interest Exemption - Contracting State is Payor1:17
Interest Exemption - Export Financing Agencies and Programme1:55
Interest Exemption - Interest paid to financial institution0:43
Interest Exemption-Credit Sales and interest on Delayed pay2:37
Interest Exemption - Tax Exempt Entities1:11
Article 11(3) - What is regarded as Interest ?5:56
Article 11(3) – Issues for Consideration1:05
Whether Premium : Discount : Profit on Instrument amount to Int4:14
Penalty charges for Late Payment - Not Interest1:19
Article 11 (4) - Interest and PE in Source State2:34
PE Situation – Interest Borne by PE2:42
Article11(5)When Shall Interest Arise in a Contracting state1:10
Case Study 4 Interest Borne by PE in other Contracting State1:41
Case Study 5-Interest Borne by PE in Third Contracting state3:04
Article 11 (6) - Excess Interest Payment to Related Party2:59
Case Study - 6 - Excess Interest Payment to Related Party0:53
Special relationship for disallowance of Excess Interest0:21
Computation of Excess Interest Payment to Related Party1:11
Interest Exemption - Other Contracting State is Recipient1:35

Requirements

Basic Knowledge of tax laws of their Home Country
Basic understanding of how Multinational Corporations derive income
Understand the meaning of basic terms used in International Tax

Description

International Taxation Course by CA Arinjay Jain is a decade old course in international taxation available online, that deals with the interpretation of tax Treaties, Global Minimum Tax, and other international tax matters, supplemented with several examples from OECD Model Tax Commentary. This course has been successfully delivered to Corporates (Industry and Big Four) and Individuals, both offline and online , where over 10,000 participants have attended the Course to grow their career .

Learning Outcomes

This International Tax online course imparts knowledge on various principles of International Taxation, which are applicable equally across countries, based on the OECD Model Tax Convention and its interpretation. The content would assist learners in shaping their careers in the International Tax Domain.

Who should take this Course?

This course has been designed from a global perspective based on the OECD Model Tax Convention and its Commentary. Since the principle of international taxation are uniform across the globe (subject to specific changes in the Treaty), the course shall be
useful for; –

Lawyers, Chartered Accountant, CPA, who are working in industry or Consulting and dealing with International Taxation matters
Tax Accountants in Practice who wish to create practice in the International Tax
Chartered Accountants in Job , to increase their knowledge and achieve greater goals
CA Students and Fresher CAs who wish to learn concepts of International Taxation
Students pursuing the following courses (The entire curriculum not covered) : –
- Advance Diploma in International Taxation
- Diploma in International Tax

Who this course is for:

Lawyers, Chartered Accountant, CPA, who are working in industry or Consulting and dealing with International Taxation matters
Tax Accountants in Practice who wish to create practice in the International Tax
Chartered Accountants in Job , to increase their knowledge and achieve greater goals
CA Students and Fresher CAs who wish to learn concepts of International Taxation
Students pursuing the following courses (The entire curriculum not covered) : – Advance Diploma in International Taxation, Diploma in International Tax

International Tax Course (DTAA)

What you'll learn

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Course content

Article 1 Persons Covered10 lectures • 1hr 11min

Article 2 Taxes Covered6 lectures • 15min

Article 4 - Resident18 lectures • 43min

Article 5 - Permanent Establishment39 lectures • 1hr 51min

Article 6 - Income From Immovable Property​7 lectures • 22min

Article 7 Business Profits15 lectures • 41min

Article 8-International Shipping And International Air Transport8 lectures • 29min

Article 9 – Associated Enterprises7 lectures • 28min

Article 10 - Dividend11 lectures • 46min

Article 11 - Interest33 lectures • 1hr 26min

Requirements

Description

Who this course is for: