24th Course on Double Taxation Avoidance Agreements – BCAS Academy | Bombay Chartered Accountants Society

The world of international tax has become extremely complex with most countries adopting the Multilateral Instrument and also seeking to tax the digitised economy. To face such an ever-changing international tax world, understanding the nuances of the Double Taxation Avoidance Agreements (DTAAs) becomes extremely important.

BCAS’ Study Course on Double Taxation Avoidance Agreements has been the flagship program in imparting this knowledge on tax treaties for the last 23 years with the faculties sharing their practical knowledge while dealing with each Article of the tax treaties.

Average Review Score:

★★★★★

You must log in and have started this course to submit a review.

Course Content

Overview of International Taxation and DTAAs

Understanding and interpreting a Tax Treaty

Overview of MLI and interplay with DTAA

Source vs Residence Principles, Source Rules under ITA and Model Conventions

Residence – with Case Studies (Including POEM and relevant MLI Provisions)

Business Connection, Significant Economic Presence and Attribution of Income

Permanent Establishment (including impact of Articles 12 to 15 of MLI)

Attribution of Profit to PE – with Case Studies

Royalties – with Case studies (Including Section 9(1)(vi) of the ITA)

FTS – FIS – with Case studies (including Section 9(1)(vii) of the ITA and reimbursements as distinguised from cost allocations)

Treaty applicability in specific situations

Interest (including 94B of ITA)

Dividend (including Article 8 of MLI)

Income from Immovable Property & Capital Gains (including Article 9 of MLI and indirect transfer provisions under ITA)

Independent & Dependent Personal Services (including Social Security Agreements), Directors’ Fees

Residuary income articles

Methods for Elimination of Double Taxation including claim of FTC (including relevant articles of MLI)

Entitlement to Treaty Benefits (including LoB Clauses in Indian DTAAs and relevant provisions of Article 7 of MLI re LOB, SLOB)

Overview of GAAR and PPT – with Case Studies (including substance over form)

Business Income (including Force of Attraction) & Associated Enterprise

TDS from payments to Non-Residents – legal concepts plus TCS on LRS

BEPS 2.0 – Pillar 1 & Taxation of Digital Economy in India (EL)

BEPS 2.0 – Pillar 2

Overview of FEMA and its relevance to International Taxation

Overview of PMLA and its relevance to International Taxation Overview of Black Money Act and disclosure of foreign income and foreign assets (including foreign social security) interplay with international tax

Overview of Transfer Pricing Regulations in India (including OECD and UN Guidelines)

Cross-border controvery management – Mutual Agreement Procedure (including relevant Articles of MLI), BAR, DRP

Presumptive tax provisions of ITA applicable to non-residents (including NRI taxation)

Taxation of specific structures (e.g., Partnership, triangular cases, AOP, etc.)

Selection of Jurisdiction

Non-Discrimination

Brain Trust Session