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    International Taxation and Transfer Pricing

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    International Taxation and Transfer Pricing

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    International Taxation and Transfer Pricing gist

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    International Taxation and Transfer Pricing gist

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    19 views2 pages

    International Taxation and Transfer Pricing

    Uploaded by

    svd053576
    International Taxation and Transfer Pricing gist

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    © All Rights Reserved
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    SYMBIOSIS INTERNATIONAL (DEEMED UNIVERSITY)

    (Established under section 3 of the UGC Act 1956)


    Re - accredited by NAAC with ‘A’ Grade
    Founder: Prof. Dr. S. B. Mujumdar, M.Sc.,Ph.D. (Awarded Padma Bhushan and Padma Shri by President of India)

    Course Name : International Taxation and Transfer Pricing


    Course Code : T1610
    Faculty : Law
    Course Credit : 2
    Course Level : 4
    Sub-Committee (Specialization) : Corporate Laws
    Learning Objectives :
    To understand the basics of international taxationTo analyse Indian and International
    norms relating to International TaxationTo appraise on the issues relating to international
    taxation such as residency, tax heavens, withholding and othersTo understand the
    basics of transfer pricing and various methods of determining transfer prices and the
    circumstances under which the various methods are optimalTo appraise on how transfer
    pricing of goods and services exchanged among divisional structures of business
    enterprises can assist the enterprise in internal resource planning, coordination for profit
    maximization, tax avoidance, exchange risk reduction in multinational corporations, and
    other goals of the firmTo analyse Indian, OECD and UN regulations relating to transfer
    pricing
    Books Book Author Publisher
    Recommended :
    STheory and Practice, The Transfer Eccles Lexington, MA:
    Pricing Problem: A Theory for Practice Lexington Books
    Basic Concepts of International Taxation Agarwal D C Taxmann, 2018
    Law Relating To Transfer Pricing With - Taxmann, 8th Ed,
    Transfer Pricing Audit 2018
    Regulation of Transfer Pricing in New York University Journal of https://heinonline.org
    Multinational Corporations: An International Law and Politics /HOL/LandingPage
    International Perspective handle=hein.journals
    /nyuilp10&div=11&id
    =&page=
    Transfer Pricing Documentation & Rajat Chawla, Richa Chawla Taxmann, 2018
    Reporting
    Course Outline : Contact
    Actual
    Sr. Hours
    Topic Teaching
    No. Equivale
    Hours
    nce
    1 Basics of International Taxation 5 5
    Meaning and Objectives of International Taxation 1.2 History and
    evolution of International Taxation 1.3 Basic principles of International
    Tax in Direct and Indirect Taxation 1.4 Types of Tax Treaties and
    Scope 1.5 Double Taxation and common practice
    2 Law relating to International Taxation 5 5
    Bilateral and Multilateral Tax Treaties 2.2 Model Treaties 2.3 UN
    Model tax treaty contents 2.4 OECD Model tax treaty contents 2.5
    Comparison between UN and OECD Models 2.6 Provisions relating
    to Double Taxation in Indian Income Tax Act, 1961 2.7 Important
    cases on double taxation
    3 Issues in International Taxation 5 5

    Page: 1
    Residency Issues 3.2 Determination of Source of Income 3.3
    Withholding Tax 3.4 Tax Heavens 3.5 Tie-breaker Rule 3.6 Concept
    of Permanent Establishment 3.7 Attribution of Profits to Permanent
    Establishment
    4 Introduction to Transfer Pricing 5 5
    Meaning of transfer pricing 4.2 Basic Principles in relation to Transfer
    pricing 4.3 Meaning of International Transaction 4.4 Concept of
    Associated Enterprises 4.5 Basic Issues underlying Transfer Pricing
    Jurisdictional issues, Allocation Issues and valuation issues 4.6
    Importance of Transfer Pricing Regulations
    5 Methods of Transfer Pricing and issues 5 5
    Arm's Length Principle 5.2 Transfer Pricing Methods Comparable
    uncontrolled price method Re-sale price method Cost plus method
    Profit-split method Transactional net margin method 5.3 Application
    of TP Methods 5.4 Transfer Price Audit and issues 5.5 Alternative to
    Arm's Length Principle 5.6 Transfer Pricing and Corporate Taxation:
    Problems, Practical Implications and Proposed Solutions 5.7
    Transfer Pricing and Intellectual Property
    6 Transfer Pricing Regulations 5 5
    OECD Manual on TP regulations 6.2 UN Manual on TP regulations
    6.3 Transfer Pricing Regulations as per Income Tax Act, 1961
    Total 30 30
    Pre Requisites :
    Course on 'Principles of Taxation Law'
    Evaluation :
    seminar presentations
    • One written test
    Group Discussion
    Presentation
    Project
    Viva
    • Cases and open problems
    • Work based Assessment
    • Multiple choice Questions
    • Learning logs/ diaries
    • Computer based Assessment
    • Reflective practice Assignments
    • Modified Essay Questions
    Pedagogy :
    1. lecture 2. Discussion3. Self-study 4. projects
    Expert :
    ,,

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