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Income Deemed to be Accrue or Arise in India
Transfer Pricing Adjustments
Advance Pricing Agreement (APA)
Determination of Tax of Non Resident in Special Cases
Presumptive Taxation for Non-Resident
Double Taxation Relief (DTAA)
Tax Treaties - Interpretation
Overview of Model Tax Conventions
Equalisation Levy
Base Erosion Profit Shifting (BEPS)
Advance Rulings

Income Deemed to be Accrue or Arise in India(No. of topics: 9)

1. Residential Status for Corporate & Non-Corporate Assessee - Outside India
2. Income deemed to accrue or arise in India - Section 9
3. Income deemed to accrue or arise in India - “Through or from any business connection in India.” - Section 9(1)(i)
4. Income deemed to accrue or arise in India - “Foreign company engaged in the business of diamond mining” - Section 9(1)(i)
5. Income deemed to accrue or arise in India - “Through or from transfer of Capital Asset situated in India.” - Section 9(1)(i)
6. Income deemed to accrue or arise in India - “If Interest is payable by” - Section 9(1)(v)
7. Income deemed to accrue or arise in India - “If Royalty is payable by” - Section 9(1)(vi)
8. Income deemed to accrue or arise in India - “If Fees for Technical Services is payable by” - Section 9(1)(vii)
9. Presence of Eligible Fund Manager in India not to constitute Business Connection in India – Section 9A

Transfer Pricing Adjustments(No. of topics: 16)

1. Transfer Pricing Implications
2. Computation of Income from International Transaction having regard to Arm’s Length Price - Section 92
3. Meaning of Associated Enterprise - Section 92A
4. International Transaction - Section 92B
5. Specified Domestic Transaction - Section 92BA
6. Computation of arm’s length price - Section 92C
7. Reference to Transfer Pricing Officer (TPO) - Section 92CA
8. Maintenance, Keeping & Furnishing of Information and Document by persons entering into International Transaction & Specified Domestic Transaction - Section 92D and Rule 10D
9. Power of Board to make Safe Harbour Rules - Section 92CB read with Rule 10TD of income Tax Rules
10. Penalties under Transfer Pricing
11. Report from an accountant to be furnished by persons entering into International Transaction or Specified Domestic Transaction - Section 92E And Rule 10E
12. Secondary adjustment - Section 92CE
13. Special Provision in respect of transaction with person located in Notified Jurisdictional Area - Section 94A
14. Specific Reporting Requirements - Country by Country Reporting - Section 286
15. Introduction - Country by Country Reporting
16. Limitation of Interest Deduction - Section 94B

Advance Pricing Agreement (APA) (No. of topics: 26)

1. Advance Pricing Agreement - Section 92CC
2. Effect to Advance Pricing Agreement - Section 92CD
3. Introduction - Advance Pricing Agreement
4. What is Advance Pricing Agreement
5. Type of Advance Pricing Agreement
6. Advantage of Advance Pricing Agreement
7. Advance Pricing Agreement Process
8. Pre-filling Consultation [ Rule 10G & 10H ]
9. Furnishing application for Advance Pricing Agreement (APA) [ Rule 10I ]
10. Acceptance/Rejection of Application of an Advance Pricing Agreement [ Rule 10K ]
11. Action By The Taxpayer, The assessing Officer And The Transfer Pricing Officer While the APA is Processed or Negotiated
12. Amendment to an APA application
13. Assignment of an APA Application To APA Team
14. Examination and Analysis of an APA Application
15. Conversion of a Unilateral APA Into a Bilateral APA
16. Entering into a Unilateral APA
17. Negotiation by the competent authority in Bilaterail / multilateral APA and entering an APA
18. Action by the Taxpayer and the Assessing Officer on entering into an APA (Section 92CD)
19. Annual Compliance Report [ Rule 10-O ]
20. Compliance Audit of The Agreement [ Rule 10P ]
21. Revision of Advance Pricing Agreement (APA) [ Rule 10Q ]
22. Cancellation of Advance Pricing Agreement (APA) [ Rule 10R ]
23. Withdrawal of an APA Application [ Rule 10J ]
24. Renewing an Advance Pricing Agreement [ Rule 10S ]
25. Provisions for Roll Back in APA Scheme [ Section 92CC(9A) read with rule 10MA ]
26. Procedure for giving effect to rollback provision of an Agreement [ Rule 10RA ]

Determination of Tax of Non Resident in Special Cases(No. of topics: 10)

1. Tax on Dividends, Interest Royalty and Fees for Technical Service in the case of Non-Corporate Non-Residents and Foreign Companies – Section 115A
2. Tax on income from units purchased in foreign currency or capital gains arising from their transfer - Section 115AB
3. Tax on income from bonds or Global Depository Receipts purchased in foreign currency or capital gains arising from their transfer – Section 115AC
4. Tax on income of Foreign Institutional Investor (FII) – Section 115AD
5. Tax on non-resident sportsmen OR sports associations - Section 115BBA
6. Tax on winning from lotteries, crossword puzzles, races including horse races, card games and other games of any sort or gambling or betting of any form or nature whatsoever - Section 115BB
7. Applicability of TDS provision on Non-Corporate Non-Resident or Foreign Company
8. Conversion of An Indian Branch of Foreign Company into Subsidiary India Company - Section 115JG
9. Exempt Income of Non-Residents
10. Other Exempt Income of Specified Foreign Entities/Non-Resident

Presumptive Taxation for Non-Resident(No. of topics: 9)

1. Taxation of NRI
2. Special provision for computing profits and gains of shipping business other than cruise shipping in case of non-residents. – Section 44B
3. Special provision for computing profits and gains in connection with the Business of Exploration etc. of Mineral Oils - Section 44BB
4. Special provision for computing profits and gains of the Business of Operation of Aircraft In the case of Non-Residents – Section 44BBA
5. Special provision for computing profits and gains of Foreign Companies engaged in the Business of Civil Construction etc. In certain Turnkey Power Projects – Section 44BBB
6. Special provision for computing profits and gains of business of operation of cruise ships in case of non-residents [ Section 44BBC Read with rule 6GB ]
7. Special provision for computing profits and gains of non-residents engaged in business of providing services or technology for setting up an electronics manufacturing facility or in connection with manufacturing or producing electronic goods, article or thing in India. [ Section 44BBD ]
8. Deduction of Head Office Expenditure in the Case of Non-Residents – Section 44C
9. Special Provisions for Computing Income by Way of Royalties, etc., in case of Non-Residents and Foreign Companies – Section 44DA

Double Taxation Relief (DTAA)(No. of topics: 4)

1. Types of Relief
2. Agreement with foreign countries or specified territories - Section 90
3. Double taxation relief to be extended to agreement between specified associations adopted by CG - Section 90A
4. Countries with which no agreement exists - Unilateral Agreements - Section 91

Tax Treaties - Interpretation (No. of topics: 13)

1. Introduction – Interpretations of Treaties
2. Tax Treaty – Overview
3. Features of Treaties
4. Role of Vienna Convention in Application and Interpretation of Tax Treaties
5. Basic Principles of Interpretation of law for interpreting a Treaty
6. Extrinsic Aids to Interpretation of a Tax Treaty
7. Approaches in Interpretation of Treaty - Static vs Ambulatory
8. Process of negotiating a Tax Treaty
9. Commentaries on OECD/UN Model Conventions and their importance
10. Foreign Courts Decisions
11. Treaty Shopping
12. Beneficial Ownership – Anti-treaty shopping measures
13. Limitation of Benefit (LoB) Clause – Anti-Treaty Shopping Measures

Overview of Model Tax Conventions (No. of topics: 36)

1. Introduction - Model Tax Conventions
2. Title and Preamble of the Model Conventions
3. Article 1 - Person Covered
4. Article 2 -Taxes Covered
5. Article 4 - Resident
6. Article 5 - Permanent Establishment
7. Article 6 - Income from Immovable Property
8. Article 7 - Business Profits
9. Article 8 - International Shipping and Air Transport
10. Article 9 - Associated Enterprises
11. Article 10 - Dividends
12. Article 11 - Interest
13. Article 12 - Royalties
14. Article 12A - Fee for Technical Services
15. Article 12B - Income from Automated Digital Services
16. Article 13 - Capital Gain
17. Article 14 - Independent Personal Services
18. Article 15 - Income from Employment / Dependent Personal Services
19. Article 16 - Director fee and Remuneration of Top Level Managerial Officials
20. Article 17 - Entertainer and Sportspersons / Artistes and Sportspersons
21. Article 18 - Pensions / Pensions and Social security payments
22. Article 19 - Government Services
23. Article 20 - Students
24. Article 21 - Other Income
25. Article 22 - Capital
26. Article 23A - Exemption Method
27. Article 23B - Credit Method
28. Article 24 - Non - Discrimination
29. Article 25 - Mutual Agreement Procedure
30. Article 26 - Exchange Information
31. Article 27 - Assistance in Collection of Taxes
32. Article 28 - Member of Diplomatic Missions And Consular Posts
33. Article 29 - Entitlement to Benefits
34. Article 30 - Territorial Extension
35. Article 31/30 - Entry into Force
36. Article 32/31 - Termination

Equalisation Levy(No. of topics: 15)

1. Introduction to Equalisation Levy
2. Definitions - Section 164 of the Finance Act, 2016
3. Charge of Equalisation Levy on 'Specified Services' - Section 165 of Finance Act, 2016
4. Charge of Equalisation levy on E-commerce supply or services - Section 165A of the Finance Act, 2016
5. Collection & Recovery of Equalisation Levy on Specified Service – Section 166, Finance Act, 2016
6. Collection and recovery of equalization levy on e-commerce supply or services – Section 166A, Finance Act, 2016
7. Furnishing of statement - Section 167, Finance Act, 2016
8. Processing of statement - Section 168, Finance Act, 2016
9. Rectification of mistake – Section 169, Finance Act, 2016
10. Interest on delayed payment of equalisation levy – Section 170 , Finance Act, 2016
11. Penalty under Equalisation Levy [ Section 171 to 173, Finance Act 2016 ]
12. Appeals under Equalisation Levy [ Section 174 & 175, Finance Act 2016 ]
13. Service of notice or communication
14. No personal appearance in the Centre for Equalisation levy
15. Consequences of furnishing false statement [ Section 176 & 177 of Finance Act, 2016 ]

Base Erosion Profit Shifting (BEPS)(No. of topics: 9)

1. Base Erosion Profit Shifting – Introduction
2. Action Plan 1 – Challenges of Taxation in Digital Economy
3. Action Plan 2 – Neutralize the effects of Hybrid Mismatch Arrangements
4. Action Plan 3 – Strengthen Controlled Foreign Company (CFC) Rules
5. Action 4 – Limitation on Interest Deduction
6. Action Plan 5 – Counter Harmful Tax Practices
7. Action Plan 6 – Prevention of Treaty Abuse
8. Action Plan 7 - Permanent establishment status
9. Action Plan 8-10 - Aligning Transfer Pricing Outcomes with Value Creation

Advance Rulings (No. of topics: 15)

1. Introduction - Advance Ruling
2. Meaning of Advance Ruling & Applicant [ Section 245N ]
3. Application for Advance Ruling From & Fee [ Section 245Q read with Rule 44E ]
4. Person entitled to sign the application under Advance Ruling [ Section 245Q read with Rule 44E ]
5. Authority for Advance Ruling [ Section 245O ]
6. Qualifications, terms and conditions of service of Chairman, Vice-Chairman and Member - Section 245OA [Inserted by FA, 2017, with effect from a date yet to be notified]
7. Vacancies, etc., not to invalidate proceedings - Section 245P
8. Procedure on Receipt of Application - Section 245R
9. Appellate authority not to proceed in certain cases - Section 245RR
10. Applicability of advance ruling - Section 245S
11. Advance ruling to be void in certain circumstances - Section 245T
12. Powers of the Authority - Section 245U
13. Procedure of Authority - Section 245V
14. Appeal against Board for Advance Ruling - Section 245W
15. Computation of Period of Limitation

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Taxpayers Must File New Application for APA Renewal After Initial Term, Following Original Procedures Without Pre-Filing Consultation

An Advance Pricing Agreement (APA) renewal requires the taxpayer to file a new application with the Director General of Income Tax (International Taxation) and the competent authority in India after the APA term expires. The renewal process mirrors the initial APA application, excluding the need for pre-filing consultation. The renewal application is treated as a fresh submission, with applicable procedures and fees. It is advisable to file the renewal request well before the existing APA's expiration.

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Renewing an Advance Pricing Agreement [ Rule 10S ]

Advance Pricing Agreement (APA)

Taxpayers Must File New Application for APA Renewal After Initial Term, Following Original Procedures Without Pre-Filing Consultation

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