indian double taxation agreements & tax laws

Indian Double Taxation Agreements & Tax Laws

By: D P Mittal (Author) | Publisher: Taxmann Allied Services Pvt. Ltd. | Publisher Imprint: Taxmann Allied Services Pvt. Ltd.

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About the Book

A Comprehensive and authentic Commentary on Indian Double Taxation Agreements with the help of decisions of International & Indian Courts as well as Authority for Advance Rulings

A comprehensive & critical study of UN Model Convention
Comparative and critical analysis of OECD Model Convention
Doing business with or in India, including e-business
Genesis and development of Treaty Models
Supremacy of a Tax Treaty over the domestic laws
Interpretation of a Tax Treaty
Classification of Income
Scope and purpose of a Tax Treaty
Taxes covered by a Treaty
Explaining definitions and expressions used in a tax treaty such as 'Resident', 'Permanent establishment', and others including 'Transfer pricing', 'Arm's length transactions', 'Treaty Shopping', etc. Explaining expressions used in domestic tax laws but not defined in tax treaties such as Income (Real Income, Fictional Income, and Substance over form). Total Income, Business, Profession, Computation of Income, etc.
Computation of income and distributive rules relating to income from Business, Shipping Business, Associates Enterprises, Capital Gains, Investment Income (dividends, interest, and royalties), Income from activities (personal and impersonal, pensions, directors' fee, entertainment, athletes, sports), Remuneration to students, etc.
Non-discrimination
Mutual agreement procedure for resolving disputes
Methods of eliminating Double Taxation, including Tax Sparing
Test of Double Taxation Agreements and Compendium of Relevant Circulars
Compendium of Rulings of Authority of Advance Rulings