1. Module I
2. Module II
3. Module III
4. Module IV
5. Module V
6. Module VI
7. Module VII
8. Module VIII

Module I - Scope of International Taxation Basics

1. Meaning of non-resident
2. Taxability of non - resident in India
3. Tax Rates and Special Provisions for tax on Dividend, Royalty, and Technical Services fees for a foreign company
4. Special Provisions for Taxability of various head of income
5. Income exemption from tax
6. Avoidance of Income Tax by transfer of income tax to Non-residents

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Module II - Computation of income from International Taxation

1. Meaning of Associated Enterprises
2. Meaning of International Transaction
3. Computation of Arm's Length Price
4. Power and duties of Transfer Pricing Officer
5. Method of computation and valuation for Transfer Pricing and in CA's Report

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Module III - Double Taxation Treaties and Relief

1. Meaning and implication of Double Taxation Treaties
2. Taxation Models
   • OECD model
   • UN model
   • US model
3. Important Articles and provisions of Model Conventions
4. Case studies of Double Taxation Treaties
   • US
   • UK
   • Singapore
5. Meaning of
   • Permanent Establishment
   • Business Taxability under the head business income
   • Business Connections

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Module IV - Authority on Advance Rulings

1. Advance Rulings
2. CBDT Circulars
3. Case laws dealing with specific situations
4. Case studies and examples

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Module V - Withholding Tax

1. Withholding tax for different heads of income as per Double Taxation Treaties for different countries
2. Deductibility of TDS on payment to a non-resident and foreign companies
3. Certificate of lower rate of tax
4. Remittance without
   • Withholding tax or TDS
   • CA certificate
   • CBDT instructions and RBI notifications
5. Agent of non-resident

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Module VI - E-commerce and International Taxation

1. Meaning and implications of E-commerce
2. Taxability of transactions in case of BPO, KPO and call centers
3. Concept of accrual of income for cross border supply of services under different four modes as defined under GATS Agreement

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Module VII - Joint Venture, Foreign Collaboration and Mergers & Acquisitions

1. Tax treatment for joint ventures and project exports
2. Taxability of intellectual property being royalty, license fees on technology transfer
3. Issues involved in mergers, demergers, takeovers, amalgamation and acquisitions etc

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Module VIII - Tax Havens and Tax Planning

1. Tax treatment under different jurisdictions and tax heavens
2. Treaty Shopping and Round Tripping
3. Taxability of different heads of income under different jurisdiction
4. Salient features of other taxation viz. Service Tax, VAT, Payroll Tax

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