LAW AND PRACTICE OF TAX TREATIES
Author(s)
Publisher
ISBN
9789350714942
Edition
2014 edition
Pages | Format
-
Approx. Product Size
1.805
A veritable Article-wise commentary on Tax Treaties duly supported by judgments of Indian as well as courts of Foreign Jurisdiction.
Also Incorporating :
- Concept and impact of DTAAs on tax position of a taxpayer.
- Treaty applicability to persons.
- Taxes covered by the Tax treaties.
- An understanding of the terms defined and undefined vis-a-vis domestic law.
- Determination of residential status & permanent establishment.
- Tax treatment of Royalty & Fees for Technical Services.
- Jurisdiction to tax income under various classifications, i.e., Immovable property, Royalty, Interest income, FTS, Professional Services, etc.
- Arresting possible tax avoidance in transactions between Associated Enterprises and Transfer pricing mechanism.
- Implications of ’limitation of benefits’ clause as in US Model Convention and in several DTAAs with India.
- Non-discrimination treatment between national, residents and PE/FB of the States.
- Mutual agreement procedure (MAP), Exchange of information (EOI) and also Mutual assistance (MA).
