Advanced Tax Laws-II

Corporate Tax Planning & Tax Management: Tax Planning, Tax Management; Tax Avoidance v/s Tax Evasion; Areas of Corporate Tax Planning; Tax Planning Management Cell.

 Double Taxation Avoidance Agreement

Residency Issues, Tax Heaven, Controlled Foreign Corporations, Concept of Permanent Establishments, Business Connection

General Anti Avoidance Rules ‘GAAR’: Basic concept of GAAR; Impermissible avoidance arrangement; Arrangement to lack commercial substance; Application of GAAR Rule; GAAR v/s SAAR.

Tax Treaties

Basics of International Taxation

i. Transfer Pricing: Introduction & Concept of Arm’s Length Price; International and Specified Domestic Transaction; Transfer Pricing Methods; Advance Pricing Agreement & Roll Back Provision; Documentation and Return.

ii. Place of Effective Management (POEM) : Concept of POEM; Guidelines of determining POEM.

Income Tax Implication on specified transactions: Slump Sale; Restructuring; Buy Back of shares; Redemption of Preference shares; Issue of shares at Premium; Transfer of shares; Reduction of share Capital; Gifts, cash credits, unexplained money, investments etc.