About Product
This book is an Authentic & Practical Book on ‘Basic Concepts of International Taxation’ that attempts to bridge the gap between conceptual aspect of an issue in international tax and the practical side of it. The Present Publication, authored by D.C. Agarwal, is the latest edition, with the following noteworthy features: This book’s objective is as follows: Provide a general idea about various Articles in the OECD Model Convention, based on OECD commentary on Model Convention and the Courts/Tribunal decisions o Explains in detail, various concepts used in OCED Model Convention o Provides comprehensive materials on these subjects for reference and guidance In line with the book’s objectives, it enables the reader for the following: o Understanding various Articles provided in the OECD Model Convention o Enabling the reader to understand various concepts used in International Taxation and apply them with greater ease and comfort o Knowing various judgements, rendered by Courts & ITAT, on the topics covered in this book o Equipping the reader for better and effective tax planning, tax assessment and defense before judicial authorities. Contents of this book are as follows: Introduction Persons Covered (Article 1 of the OECD MC) Taxes Covered (Article 2 of the OECD MC) General Definitions (Article 3 of the OECD MC) Subject to Tax (Relating to Article 1 of OECD MC) Source vs. Residence (Article 4 of OECD MC) Place of Effective Management (Relating to Article 4 of OECD MC) Permanent Establishment (Article 5 of OECD MC) Income from Immovable Property (Article 6 of OECD MC) Business Profits (Article 7 of OECD MC) Force of Attraction (Relating to Article 7 of OECD MC) Income from Shipping and Aircraft Business (Article 8 of OECD MC) Associated Enterprises (Article 9 of OECD MC) Transfer Pricing (Relating to Article 9 of OECD MC) Dividend (Article 10 of OECD MC) Taxation of Interest (Article 11 of OECD MC) Royalty (Article 12 of OECD MC) Fees for Technical Services (Relating to Article 12 of OECD MC) “Make Available” (Relating to “Fee for Technical Services”) “May Be Taxed” and “May Also Be Taxed” Capital Gains (Article 13 of OECD MC) Independent Personal Services (Articles 14 of OECD MC)(Deleted) Income from Employment (Article 15 of OECD MC) Director’s Fees (Article 16 of OECD MC) Entertainers and Sportspersons (Article 17 of OECD MC) Pensions (Article 18 of OECD MC) Government Service (Article 19 of OECD MC) Other Income (Article 21 of OECD MC) Students (Article 20 of OECD MC) Capital (Article 22 of OECD MC) Foreign Tax Credit (Article 23 of OECD MC) Non-Discrimination (Article 24 of OECD MC) Treaty Shopping Tax Sparing Tax Evasion and Tax Avoidance Double Taxation/Double Non-Taxation Interpretation of Statutes and Tax Treaties Withholding Tax Limitation of Benefit Rule Tax Havens Treaty Override Thin Capitalization Beneficial Ownership Mutual Agreement Procedure (Article 25 of OECD MC) Exchange of Information (Article 26 of OECD MC) Assistance in the Collection of Taxes (Article 27 of OECD MC) Members of Diplomatic Mission and Consular Posts (Article 28 of OECD MC) Territorial Extension (Article 29 of OECD MC) Entry into Force (Article 30 of OECD MC) Termination (Article 31 of OECD MC)
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