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International Taxation.

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August 28, 2022 |

36 mins read

International taxation, is an area of tax, where tax is determined, in respect of an income, which is earned by a tax resident of one country, from business operations, rendering of services, employment, capital gains, dividend, interest or any other income, in another country.In such cases, both the country where the income arises,as well as the country where the person earning the income is a tax resident, seek to levy and recover tax.The international tax advisor interprets rules of international taxation, ensure that such income is taxed in only in one of the countries, or in case it is typed in both the countries, the overall tax burden is not more than, the higher of the tax rate applicable in either of the countries.

Tax International Taxation
Author CA Arinjay Jain
Topics Covered DTAA, Transfer pricing, NR Taxation, AAR, Double taxation relief, Black money act, Interpretation of tax treaties, Anti Avoidance Measures, Ecommerce Transactions, FDI, GMT

International Taxation Course

International Tax Interpretation of Tax Treaties (DTAA)

For the purpose of international tax, and avoidance of double taxation, countries enter into DTAA, which generally contains various Article. Each of these article either deal with a different type of income, provides for method through which double taxation can be avoided or eliminated.
An international tax advisor interprets the concept of double taxation in international tax through reading of various article that are discussed as under:

International Taxation Course

Transfer Pricing in International Taxation

Transfer Pricing provisions are used for arriving at the arm’s length price, that should be charged for, product sold or services rendered, by one enterprise, to another enterprise, who are a part of the same multinational group.

By using arms length price, both for revenue as well as expenses, the profits on which tax are paid, are ascertained correctly. Transfer pricing is an integral part of international tax services, in determination of tax on international transactions.

Non Resident Taxation – International taxation

This section deals with various topics which are a part of international tax advisory services, including specifically the determination of residential status, income which is deemed to accrue or arise in India, certain presumptive basis of taxation in respect of specified income of non resident, deduction of TDS on various payments to non resident, taxation of capital gains arising to non residents and multiple choice question, which deal with various practical situations relating to the taxation of non resident in India.

We provide international taxation consultancy, in respect of each of these topics. Our international tax advisory services are provided by professionals with over two decades of experience in international taxation.We also, assist company in international tax compliance, relating to their business operations in India.

International Taxation Services

Authority for Advance Rulings

An international tax advisor can assist you in obtaining an Advance Rulings, through which, you can be certain about the amount of taxes that should be applied for, a transaction that you may undertake in the State of Source:

Double Taxation Relief – International Tax

Our international tax expert, can help you compute the right amount of taxes payable in India. Further our international tax specialist can also assist you in claiming the credit of taxes that you may have paid overseas, against your Indian tax liability.

Black Money and Imposition of Tax Act 2015

International Taxation Services

Interpretation of Tax Treaties – International Taxation

Anti Avoidance Measures

Our international tax specialist can review your tax structure and advice whether the overall business operations structure, shall meet the requirement of the Indian general Anti Avoidance Regulations.

Taxation of Ecommerce Transactions

International Taxation Services

International Tax Case Studies

The following case studies have been prepared by our team of international tax specialist, considering the provisions of international tax income tax applicable in India.
Each of these cases deal with a specific situation. in case you need any further advisory services in respect of the case studies, you may please feel free to reach out to us.

Foreign Direct Investment

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Arinjay Jain

Bio of author

Arinjay is a Chartered Accountant with more than 20 years of post-qualification experience. He worked as Director, in the M&A Tax Division at KPMG in India. Presently, he is advising several MNCs in UAE on Economic Substance Regulations and impact of the UAE Corporate Tax Law on their business and clients across globe on International Tax issues . He is a well recognised Trainer of International Tax and UAE Corporate Tax. The areas of service include the following : - Advise and Compliance relating to International Tax Issues; Advise relating to UAE Corporate Tax Issues; Advise and Compliance relating to UAE Economic Substance Regulations; Advise and Compliance relating to Indian Income Tax Issues; Other connected matters from a Regulatory perspective.

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    As an International Tax Consultants, we provide services for FDI, Inbound & Outbound Investment and Transfer Pricing

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FAQs

What is a DTAA ?

DTAA, also referred to as a Double Taxation Avoidance Agreement or Tax Treaty, refers to an agreement between two countries , with the aim to address and prevent double taxation of the same source of income. The agreement puts safeguards in place that ensure that an income once taxed in one Contracting State does not suffer taxation in the other Contracting State either at all, or if it is subjected to tax, tax paid in other contracting state is reduced from such tax.

What is Transfer Pricing ?

The price at which international transactions takes place is called Transfer Price. Transfer Pricing provisions are used for arriving at the Arm’s Length Price that should be charged for, product sold, or services rendered, by one enterprise, to another enterprise, who are a part of the same multinational group.

What is FDI ?

Foreign Direct Investment or FDI in India as it is commonly called refers to investment in capital instruments of Indian companies by non-residents.