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DTAA - International Taxation Course Overview
with CA Sachin Sinha
Course Fees: ₹4999
Offer Price: ₹4500
inclusive of all taxes- Faculty: CA Sachin Sinha
- Date: 24th March to 30th March
- Time: 7:00 PM - 8:30 PM
- Duration: 10.5 Hours
- Language: English
- Validity: 3 Months
Course Introduction
This 7-day course will offer an in-depth understanding of the Double Taxation Avoidance Agreement (DTAA) framework, its key articles, and their applications in international taxation. The course will cover the foundational principles, technicalities, and procedural aspects of DTAAs, with a strong emphasis on their practical implementation for professionals. Below is a broad outline of the content to be covered over the span of the course.
Day 1: Introduction & Articles 1, 2, 3, and 4
- *Overview of DTAA:*
- Concept and purpose of Double Taxation Avoidance Agreements (DTAA)
- Key objectives: Preventing double taxation, promoting cross-border trade & investment, and resolving conflicts in taxation
- *Article 1 - Persons Covered:*
- Defining which persons (individuals, entities) are covered under the treaty.
- Scope of application for residents of contracting states.
- *Article 2 - Taxes Covered:*
- Taxes covered under DTAA (income tax, capital gains tax, etc.).
- Scope of different taxes covered by bilateral treaties.
- *Article 3 - General Definitions:*
- Definitions of critical terms such as "resident," "national," "income," etc.
- Understanding the terminologies used across the agreement.
- *Article 4 - Residence:*
- Criteria to determine the "residence" of individuals or entities.
- Tie-breaker rules when an individual or entity is a resident of both contracting states.
Day 2: Articles 5 and 6
- *Article 5 - Permanent Establishment (PE):*
- Definition and significance of PE in international taxation.
- Types of Permanent Establishment (e.g., branch, office, factory, construction site).
- Impact of PE on taxation rights between the contracting states.
- *Article 6 - Income from Immovable Property:*
- Taxability of income derived from immovable property.
- Allocation of rights to tax between the two contracting states on income from property.
Day 3: Articles 7, 8, 9, and 10
- Article 7 - Business Profits:*
- Understanding the taxation of business profits under the DTAA framework.
- Allocation of taxation rights on business profits between the two states.
- *Article 8 - Shipping and Air Transport:*
- Special rules regarding the taxation of profits from international shipping and air transport.
- Exemptions or reduced tax rates available in the case of shipping and air transport.
- *Article 9 - Associated Enterprises:*
- Definition and concept of associated enterprises.
- Transfer pricing and its relevance in international taxation.
- Allocation of profits among associated enterprises.
- *Article 10 - Dividends:*
- Taxability of dividend income.
- Reduction of withholding tax rates on dividends.
- Impact of treaty provisions on dividend taxation.
Day 4: Articles 11, 12, and 13
- Article 11 - Interest:*
- Taxation of interest income under DTAA.
- Reduced tax rates on interest through treaties.
- *Article 12 - Royalties and Fees for Technical Services:*
- Taxation of royalties and fees for technical services.
- Allocation of tax rights between the contracting states on royalties and technical services.
- *Article 13 - Capital Gains:*
- Taxability of capital gains.
- Exemptions or reduction in tax rates on capital gains arising from the sale of property or shares.
Day 5: Articles 15, 16, 17, and 18
- Article 15 - Employment Income:*
- Taxation of income from employment.
- Rules governing the taxation of income earned by employees in foreign countries.
- *Article 16 - Directors' Fees:*
- Taxation of directors’ fees under the DTAA.
- Clarifying the allocation of taxation rights between contracting states.
- *Article 17 - Artistes and Sportsmen:*
- Taxation of income of entertainers, athletes, and sports professionals.
- Provisions to prevent double taxation of income earned through performances.
- *Article 18 - Pensions:*
- Taxation of pension income.
- How pensions are taxed in both the home country and the country of residence.
Day 6: Articles 19, 20, and 21
- Article 19 - Government Service:*
- Tax treatment of income derived from government services.
- Clarifying the rules regarding taxation in the country of service versus the country of residence.
- *Article 20 - Students and Trainees:*
- Exemptions for students and trainees under DTAA.
- Rules for taxation of educational grants and stipends.
- *Article 21 - Other Income:*
- Taxation of income not specifically covered under other articles of the treaty.
- General principles for taxing other income types.
Day 7: Articles 22 and 23 & Treaty Procedure
- Article 22 - Non-Discrimination:*
- Preventing discriminatory taxation practices.
- Ensuring that nationals and residents of one country are not treated unfairly in the other contracting state.
- *Article 23 - Mutual Agreement Procedure:*
- Mechanism for resolving disputes between contracting states.
- How to use the Mutual Agreement Procedure (MAP) to settle issues related to taxation under the treaty.
- *Other Procedure Aspects:*
- *How a DTAA comes into effect:*
- Explanation of the procedural aspects of how treaties are negotiated, signed, and ratified.
- The process for implementing a new treaty and its application in domestic law.
- *Updating and Amending Treaties:*
- Procedure for renegotiating existing treaties and handling amendments.
- *Practical Case Studies:*
- Overview of how DTAAs are practically applied in international business scenarios.
Conclusion & Wrap-Up
- Recap of key articles covered during the course.
- Case studies and real-life examples to understand the application of DTAA in various contexts.
- Discussion on recent changes or updates in international tax laws, if applicable.
Course Highlights
E-Notes: Comprehensive PDF
Detailed reference materials for your learning journey
Interactive Q&A sessions
Get your doubts cleared after each live class
E - Certificate of Edukating
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3 Months Recording Access
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About Faculty
CA Sachin Sinha
is Fellow member of ICAI having 20 years of experience. He is Founder Partner of Prakash Sachin & Co, Chartered Accountants.
He has in hand experience of Taxation (domestic and international taxation) and Management Consultancy. He has developed himself in the advisory and litigation and handling other Commercial issues.
He is associated with Chamber of Tax consultants. He has deliberated in around 400 seminars and webinars so far on the topic of Domestic and International Taxation and written many articles on the same subject for various knowledge portals including Taxmann.com.
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