Description
Taxmann International Taxation Ready Reckoner 1st Edition April 2023 by Daksha Baxi, Surajkumar Shetty
This book is India’s first ‘ready reckoner’ with a specific focus on international taxation & taxation of cross-border transactions. It covers the entire spectrum of topics, which are as follows:
Basic provisions of the scheme of taxation in India
Residence in India
Role of Double Taxation Avoidance Agreements (DTAA)
Interaction of DTAA with the Income-tax Act
How to read a DTAA?
How to determine eligibility for DTAA?
How to resolve the conflict between a DTAA & Income-tax Act?
It is an essential handbook for anyone who is dealing with cross-border transactions, including:
Payments made to non-residents
Transactions with non-residents
Digital transactions
Withholding tax obligation obligations of residents
The Present Publication is the 1st Edition and has been amended by the Finance Act 2023. This book has been authored by CA Daksha Baxi & Adv. Surajkumar Shetty with the following noteworthy features:
[Exhaustive Coverage] of the tax implications on cross-border transactions
[Evaluating the Taxability] using the following:
Income-tax Act
Double Taxation Avoidance Agreement
Reference to Rules, Forms, Circulars, etc.
Reference to Case Laws
[Authors’ Notes] are given for the following:
How should an advisor approach the transaction?
What investigations should be made to apply the law and principles of the Income-tax Act & Double Taxation Avoidance Agreement?
[Conceptual Analysis in Simplified Language with Examples & Case Laws] for the following ‘noted’ topics, among others:
Place of Effective Management
Permanent Establishment
Business Connection
Foreign Portfolio Investors
Investment Funds & their Investors
Alternative Investment Funds (AIFs)
Infrastructure Investment Funds (InvITs)
Real Estate Investment Trusts (REITs)
Securitisation Trust
[Covering Provisions relating to Litigation Proceedings] under the following:
Income-tax Act
Mutual Agreement Procedure (MAP) under the Double Taxation Avoidance Agreement
Authority for Advance Ruling (AAR) Process
Equalisation Levy
Transfer Pricing Provisions
General Anti Avoidance Rules (GAAR)
Special Provisions for International Financial Services Centres (IFSC)
[Illustrations/Examples, Practical & Comprehensive Case Studies] are given to provide insights into the finer nuances of cross-border transactions
The detailed contents of the book are as follows:
Tax System for Non-Residents in India – An Overview
Tax Treaties
Setting Up a Business in India
Classification of Income
Determining Eligibility to Claim Benefits of DTAA
Taxation of Rental Income
Taxation of Business Income
Taxation of Dividend Income
Taxation of Interest Income
Taxation of Royalty Income
Taxation of Income from Fees for Technical Services
Taxation of Capital Gains
Taxation of Employment Income
Taxation of Non-Resident Indian
Taxation of Foreign Portfolio Investors
Taxation of AIFs, REITs, InvITs, Securitisation Trust
Transactions Attracting Transfer Pricing Regulations
Business Reorganisations
Discontinuance of Business and Dissolution of Indian Company
Foreign Tax Credit
Making Payments to NRs & Obtaining Lower Withholding Certificate
Assessments, Appeals and Dispute Resolution
General Anti-Avoidance Rules
Miscellaneous
Case Study to Determine Taxability of NR, under the IT Act & DTAA