Law and Practice of Tax Treaties

  • Author : R.P Garg  Beenu Yadav  
  • Edition : 2014 Edition
  • Date of Publication : July 2014
  • ISBN No.:9789350714942
  • Binding : Hardbound
  • No. Of Pages : 1572
  • Weight (Kgs) : 1.805
INR 2250 | USD 80
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Description

A veritable Article-wise commentary on Tax Treaties duly supported by judgments of Indian as well as courts of Foreign Jurisdiction.

Also Incorporating :
  • Concept and impact of DTAAs on tax position of a taxpayer.
  • Treaty applicability to persons.
  • Taxes covered by the Tax treaties.
  • An understanding of the terms defined and undefined vis-a-vis domestic law.
  • Determination of residential status & permanent establishment.
  • Tax treatment of Royalty & Fees for Technical Services.
  • Jurisdiction to tax income under various classifications, i.e., Immovable property, Royalty, Interest income, FTS, Professional Services, etc.
  • Arresting possible tax avoidance in transactions between Associated Enterprises and Transfer pricing mechanism.
  • Implications of ’limitation of benefits’ clause as in US Model Convention and in several DTAAs with India.
  • Non-discrimination treatment between national, residents and PE/FB of the States.
  • Mutual agreement procedure (MAP), Exchange of information (EOI) and also Mutual assistance (MA).


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