International Tax - Tax Beyond boundaries
4.6 (9 ratings)
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International Tax - Tax Beyond boundaries

Comprehensive Course on Article by Article analysis of Tax Treaty to understand all aspects of International Tax
4.6 (9 ratings)
Instead of using a simple lifetime average, Udemy calculates a course's star rating by considering a number of different factors such as the number of ratings, the age of ratings, and the likelihood of fraudulent ratings.
47 students enrolled
Last updated 9/2016
English
Current price: $10 Original price: $50 Discount: 80% off
5 hours left at this price!
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Includes:
  • 19.5 hours on-demand video
  • Full lifetime access
  • Access on mobile and TV
  • Certificate of Completion
What Will I 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
View Curriculum
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

This Course is meant for learners who want to learn, explore and enhance their knowledge on the complex area of International Tax. The course has been divided into 29 Sections, each comprising of a particular Article dealing with International tax. We have used India USA Treaty as a basis of explaining various concepts and judicial precedents in India as a basis for explaining various concept, but the explanation can help anyone understand the concept of International Tax. 

Whether it is concept of Resident, existence of Permanent establishment, Income from immovable property, Taxation of Shipping, inland waterways transport and air transport, Dividends, Interest, Fee for technical services & Royalties, Capital gains, Independent Personal services, Directors's fees, Artistes and sportsmen amongst others. This Course is not a professional advise and hence before deciding on any practical case study, proper expert advise should be obtained.

Who is the target audience?
  • This International Tax Course is meant for Chartered Accountants and CPA, who are working with consultancy firms providing International Tax Services to their clients who are either Multinationals or provide services to Multinational Corporations
  • Professionals in industry working for Multinational Corporations
  • Finance Professionals to understand how taxes could influence the cash management
  • Individuals looking at being part of Tax authorities of a country looking to understand Global tax provisions impacting Multinationals
Compare to Other Tax Preparation Courses
Curriculum For This Course
235 Lectures
19:37:20
+
Introduction to the Course
1 Lecture 01:32
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Article 1 - Person Covered
22 Lectures 01:10:34

Need for a tax treaty in International Trade - Part 2
00:55

Learn about What is a Tax Treaty
What is a Tax Treaty
03:41

Learn about Various Models of Tax Treaties - UN, OECD and US Model
Various Models of Tax Treaties - UN, OECD and US Model
02:55

Learn about What are the key considerations for the Contracting Countries at the time of entering into Tax Treaty
What are the key considerations for the Contracting Countries at the time of ent
02:19

Learn about Contents of a Tax Treaty - Various Clauses
Contents of a Tax Treaty - Various Clauses
03:38

Learn about Contents of a Tax Treaty - Various Clauses
Consideration of tax treaties - Not only tax
04:13

Learn about Provision of Income Tax Act, 1961 vs. Tax Treaty - Section 90(2) - Which one should be preferred
Provision of Income Tax Act, 1961 vs. Tax Treaty - Section 90(2)
05:39

Learn about General provisions of Tax Treaty
General provisions of Tax Treaty
05:35

Learn about Impact of subsequent amendment of Income Tax Act, 1961 on earlier tax Treaties
Impact of subsequent amendment of Income Tax Act, 1961 on earlier tax Treaties
03:31

Learn about If an income is Taxable under the Income Tax Act, 1961, but there is  no corresponding clause in Treaty/  Condition of relevant clause not satisfied(2)
Income Taxable under domestic law but no corresponding Treaty clause
01:43

Learn about Withholding tax - Governing rules vis a vis Tax Treaties
Withholding tax - Governing rules vis a vis Tax Treaties
04:32

Learn about Interpretation of Treaties - Liberal or Strict
Interpretation of Treaties - Liberal or Strict
01:54

Learn about If an income is Taxable under the Income Tax Act, 1961, but there is  no corresponding clause in Treaty/  Condition of relevant clause not satisfied(2)
11. Taxable under the Act but Treaty condition for tax not satisfied
03:43

Learn about Tools for Interpreting Treaties - Protocol, Technical Expalnations, Mode Commentary, Case laws and others
Tools for Interpreting Treaties - Protocol, Technical Expalnations, Commentaries
03:10

Learn about Vienna Convention on Law of Treaties as an aid to Treaty Interpretation
Vienna Convention on Law of Treaties as an aid to Treaty Interpretation
02:53

Learn about Purpose of Model Commentaries - OECD and UN Model
Purpose of Model Commentaries - OECD and UN Model
02:50

Learn about Purpose of Model commentaries & India's stand on OECD Commentary
Purpose of Model commentaries & India's stand on OECD Commentary
04:14

India's stand on UN Model Convention and UN Commentary
01:48

Learn about Other aids for Interpreting Treaties
Other aids for Interpreting Treaties
02:58

Learn about Different views by two contracting states
Different views by two contracting states
03:23

Learn about Interpretation of "words" used in Treaty - Treaty definition vs Income Tax Act, 1961 provision vs general meaning
Interpretation of "words" used in Treaty - Treaty definition vs Income Tax Act,
02:09
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Article - 2 - Taxes Covered
6 Lectures 32:08
Learn about What are the taxes which are covered in Tax Treaty under Article 2 and Importance of  Article 2 in tax laws
Preview 06:57

Learn about draft Article 2 of India- Netherlands and India- USA Treaty
Understanding draft Article 2 of India- Netherlands and India- USA Treaty
09:24

Learn about  Key Features and Coverage of Article 2 relating to taxes
Key Features and Coverage of Article 2 relating to taxes
02:36

Learn about What is regarded as Taxes on income and on capital
What is regarded as Taxes on income and on capital
07:47

Learn about Key feature of article 2(2) of India USA Treaty
Key feature of article 2(2) of India USA Treaty
00:55

Learn about Article 2(3) - Specific countrywide taxes which are covered
Article 2(3) - Specific countrywide taxes which are covered
04:29
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Article - 4 - Residence
10 Lectures 57:53
 Learn about the general structure of ARTICLE 4, Importance of concept of residence, Categories of taxpayers who are covered as Resident and whether a person who is liable to tax in a State by certain specified  reason can be considered as a resident 
Who are Resident - Article 4(1)
07:28

Learn about what would amount to  "being liable to tax"  in a Country, which should be satisfied to become a resident
Preview 01:55

Learn whether Sovereign Funds and Collective Investment Vehicles are tax resident of a given State
Sovereign Funds and Collective Investment Vehicles - Tax residency
04:44

Meaning of the Term Resident and Person
Meaning of the Term Resident and Person
02:38

How to harmonise the provision of Article 4(1) and provision of Income Tax Act 1961 to conclude if a person is a resident of a Contracting State
Interplay of Article 4(1) and Income Tax Act 1961
02:07

Person who are considered as not taxable in  a country and therefore do not satisfy the condition of being "Liable to tax therein"
Liable to tax therein - Person who are not taxable
15:10

Learn about what documents/ declaration/proofs are required in order to establish that a person is a resident of a Contracting State
Proof of being a resident of a Contracting State
03:14

Learn about the Tie breaker Rule in case of an individual - If an individual becomes a resident of two countries by application of Article 4, how should he be considered as a resident of only one country
Article 4(2) - Tie breaker Rule in case of an individual
06:34

Aspects to be considered in application of Tie breaker Rule - Permanent Home, centre of Vital Interest, Habitual abode and Nationality
Permanent Home, centre of Vital Interest, Habitual abode and Nationality
06:26

Learn about the applicability of Tie breaker rule to a  person other than an individual - Article – 4(3)
Article – 4(3) – tie breaker rule – person other than an individual
07:37
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Article 5 - Permanent Establishment
12 Lectures 01:42:44
Learn about  Basics of Permanent Establishment and Business connection and there relevance in taxing business profits
Basics of Permanent Establishment and Business connection
05:02

Learn about  Concept of Business Connection and Permanent Establishment under the Income Tax Act, 1961
Concept of Business Connection and Permanent Establishment under the Income Tax
07:57

Characterstics of Permanent Establishment and key components of the Presentation
05:47

Learn about  Fixed Place of Business Permanent Establishment - Article 5(1)
Fixed Place of Business Permanent Establishment - Article 5(1)
14:25

Learn about  What all is covered under  Article 5
What all is covered under Article 5
03:48

Learn about  Meaning of "Business carried on by the PE" and certain Case studies on PE
Meaning of "Business carried on by the PE" and certain Case studies on PE
05:31

Learn about  Article 5(2) - Certain specific inclusion in Permanent Establishment and Construction and Installation PE
Article 5(2) - Certain specific inclusion in Permanent Establishment and Constru
16:37

Learn about  Service Permanent Establishment
Service Permanent Establishment
06:40

Learn about  Auxilliary or Preparatory Activities which do not result into a Permanent Establishment
Auxilliary or Preparatory Activities which do not result into a PE
10:15

Learn about  Agency Permanent Establishment - Dependent Agent
Agency Permanent Establishment - Dependent Agent
14:07

Learn about  "Habitually securing orders" in the Source State for NR resulting into Dependent Agent Permanent Establishment
"Habitually securing orders" in the Source State for NR
04:05

Learn about  Article 5(5)  -  Independent Agent Permanent Establishment
Article 5(5) - Independent Agent Permanent Establishment
08:30
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Article 6 - Income from Immovable Property
5 Lectures 16:30
Learn about What is taxable under Article 6 -  Immovable Property
Preview 03:17

Learn about What are the Right of India and Treaty partner to tax income from Immovable Property
Right of India and Treaty partner to tax income from Immovable Property
04:05

Learn about What are the Key Issues in Article 6(1)  - Location of property, computation of income
Key Issues in Article 6(1) - Location , computation of income
04:08

Learn about Meaning of " immovable property" and "Property used for providing Independent Personal Services"
Meaning of " immovable property" and "Property used to provide IPS
04:04

Learn about Computation of income from immovable property
Computation of income from immovable property
00:56
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Article 7 - Taxation of Business Profits
11 Lectures 01:07:33
Learn about  Steps to be followed for ascertaining applicability of Article 7 - Business Profits
Steps to ascertain applicability of Article 7 - Business Profits
09:04

Learn about  Structure of various clauses covered under Article 7 of the India USA Treaty
Structure of various clauses covered under Article 7 of the India USA Treaty
02:15

Learn about Right of the Source State to tax Business Profits and which profits are taxable in Source State under Article 7(1)
Right of the Source State to tax Business Profits and which profits are taxable
08:26

Learn about  Computing profits attributable to a PE under Article 7(2)
Computing profits attributable to a PE under Article 7(2)
15:50

Learn about Expenses allowed as a deduction in computing income of the PE and cross charges etc  - Article  7(3)
Expenses allowed as a deduction in computing income of the PE and cross charges
12:19

Turnkey Contract and taxation of resulting PE/ offshore services in SourceState

Turnkey projects
05:37

Learn about  Mere purchase of goods by PE and attribution of income - Article  7(4)
Mere purchase of goods by PE and attribution of income - Article 7(4)
03:12

Learn about Profits from assets and activities of the PE - Article 7(5)
Profits from assets and activities of the PE - Article 7(5)
03:07

Learn about Taxation of items dealt with in other Article where recipient has a PE in India - Article 7(6)
Taxation of items dealt with in other Article where recipient has a PE in India
02:25

Learn about Meaning of business profits under  Article 7 (7) 
Meaning of business profits under Article 7 (7)
01:51

Learn about Rule 10 of the IT Rules - Allocation of profits to NR
Rule 10 of the IT Rules - Allocation of profits to NR
03:27
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Article 8 - Taxation of Shipping and Air Transport Profits
9 Lectures 38:34
Learn about Profits from Shipping or Aircrafts business - Right to tax and condition for taxation under Article 8
Profits from Shipping or Aircrafts business - Right to tax and condition for tax
10:03

Learn about Understanding impact of Place of Effective Management in Taxation of Shipping and Airline Profits
Preview 03:32

Learn about Conditions for applicability of Article 8 and income excluded from Article 8 
Conditions for applicability of Article 8 and income excluded from Article 8
02:55

Learn about Engineering Services to other Airlines - Whether covered under Article 8 of India UK Treaty as Airline profits
Engineering Services to other Airlines - Whether covered under Article 8 of Indi
02:06

Learn about Article 8(2) – Meaning of Profits from operation of ships and aircrafts, Meaning of Inland Waterways
Article 8(2) – Meaning of Profits from operation of ships and aircrafts, Meaning
10:10

Learn about Article 8(3) – Profit from containers
Article 8(3) – Profit from containers
01:43

Learn about Article 8(4) – Taxation of Profit from participation in a joint pool
Article 8(4) – Taxation of Profit from participation in a joint pool
02:15

Learn about Article 8(5) – Interest on funds connected with operations of Shipping and Airlines
Article 8(5) – Interest on funds connected with operations of Shipping and Airli
03:19

Learn about Activities covered and excluded by Article 8
Activities covered and excluded by Article 8
02:31
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Article 9 - Associated Enterprise
10 Lectures 44:00
 Learn why the concept of Associated Enterprise is important and what it means
What are Associated Enterprise
03:17

Learn when two  enterprise are AE under Article 9(1) and when are two Enterprise AE under IT Act
Components of Associated Enterprise
02:19

Circumstances under which two entities become Associated Enterprise under Article 9(1) of INDIA -  USA treaty
Associated Enterprise - Article 9(1)
09:46

CONTROL is the Power to administer , manage, direct, restrict, regulate, or govern.
Meaning of Control
01:09

Case Study on Excessive expenditure disallowance under Article 9(1)
Case Study on Excessive expenditure disallowance under Article 9(1)
02:18

Article 9(2) - Coorelative adjustments alongwith case studies and example
Article 9(2) - Coorelative adjustments alongwith case studies and example
06:09

Secondary adjustment are adjustments which when made restore the taxation of income to exact levels, where it would have been if the transactions had taken place at arm’s length in the beginning – 
Concept of Secondary Adjustment
02:43

Price influenced by purchasers of article, Common individual/relative control, Huf cases, Ownership of more than 10% in firm/aop/boi and Other prescribed relationship
Preview 04:58

Definition of AE under IT Act - Direct or Indirect Holding of 26% or more voting power in the Enterprise, Common person/ enterprise has direct or Indirect holding of 26% or more voting power in two Enterprise and "Definition of AE under IT Act - Direct or Indirect Holding of 26% or more voting power in the Enterprise, Common person/ enterprise has direct or Indirect holding of 26% or more voting power in two Enterprise "
Associated Enterprises as per IT Act - Part 2
07:06

Guarantee of not less than 10% of total borrowings, Appointment by enterprise of board of directors or members of the governing board and Appointment by same person - board of directors or members of the governing board and Know how etc. used in manufacture or processing of goods or articles, Raw material / consumables required for manufacture or processing of goods or articles
Associated Enterprises as per IT Act - Part 3
04:15
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Article 10 - Dividend
8 Lectures 40:33
Learn about  Key aspects to be covered in Article 10 - Dividend
Preview 04:57

Learn about Meaning of Dividend
Meaning of Dividend
02:39

Learn about Right to tax dividend, what is covered as dividend and meaning of dividend paid alognwith several examples - Article 10(1)
Right to tax dividend, what is covered as dividend and meaning of dividend paid
03:17

Learn about Right of Source State to tax Dividend - Part 1 - Conditions and examples on beneficial ownership
Right of Source State to tax Dividend - Part 1 - Beneficial ownership
08:16

Learn about Beneficial ownership and right to opt for provision of Income Tax Act, 1961,  if they are more beneficial
Beneficial ownership and right to opt for provision of Income Tax Act, 1961
06:21

Learn about Meaning of Dividend - Article 10(3)
Meaning of Dividend - Article 10(3)
06:20

Learn about PE or Fixed base and taxation of dividend - Article 10(4) 
PE or Fixed base and taxation of dividend - Article 10(4)
03:36

Learn about Right to tax dividend declared by foreign company deriving income from  State of Residence or third State
Right to tax dividend declared by foreign company
05:07
19 More Sections
About the Instructor
Mr. Arinjay Kumar Jain
4.6 Average rating
9 Reviews
50 Students
3 Courses
International Tax Expert and Former Director at KPMG India

I am an expert in International Taxation and M&A tax structuring wherein I have worked with KPMG as a Director in Indian practice helping large number of MNC, as well as domestic companies in the are of Inbound Investments, Outbound acquisition, cross border tax structuring, amalgamation, demerger, business sale amongst others. I have been a visiting faculty and have taught over 1500 professional students,  until date taught over 20000 students through online effort to promote philanthropy in basic education.