Direct Tax and International Taxation

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

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.

Taxation of Companies,: Tax incidence on Companies including foreign company; Minimum Alternate Tax ‘MAT’; Dividend Distribution Tax; Alternate Minimum Tax ‘AMT’;

Taxation of LLP and Non-resident: Tax incidence on LLP; Taxation of Non-resident Entities.

Tax Treaties: Introduction, Double Taxation, Double Taxation Relief, Objectives of Tax Treaties, Application of Tax Treaties,  Interpretation of Tax Treaties, Process of Negotiating Tax Treaties, Relationship between Tax Treaties & Domestic Law , Tax Information Exchange Agreement (TIEA), DTAA Treaty With Argentina – Bare View

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.