Diploma in Tax Litigation and Advanced Corporate Taxation

LawSikho

Online

6 Months

₹ 60000

particular

details

                                    Medium of instructions
                                    English

                                    Mode of learning
                                    Self study, Virtual Classroom

                                    Mode of Delivery
                                    Video and Text Based

                                    Frequency of Classes
                                    Weekdays, Weekends

                                    Learning efforts
                                    8-10 Hours Per Week
                                

Tax on Business Income

Essential tax components
- Business Income from running a business
- Capital Gains on sale of shares or assets
- Salaries and profits earned by directors or owners
- License or any other fees earned by directors
Tax on business income:
- Individuals/ Proprietorships
- Partnerships
- LLPs
- Companies
- Private trusts
Minimum Alternate Tax (MAT) and its applicability
Tax on Distribution of Profits of a Company
Exemptions on Public Trusts
Taxation of trustees and representative assessees
How to secure tax exemption
Tax exemptions for ‘startups’

Tax On Executive Remuneration: Assessment And Litigation Proceedings

Tax on Consultancy Fees and Royalty
Tax on Salary and Bonus
Tax on Profit Share
Tax on ESOPs and Sweat Equity
Clubbing of income and exceptions

Tax Deduction At Source/ Withholding Tax: Key Litigious Issues In Domestic And International Tax

Key heads for TDS deduction
- Income from Salary
- Rental Income
- Dividend Income
- Interest Income
- Income from Other Sources
When is TDS not to be deducted?
Should TDS be deducted for non-taxable income?
Consequences of not deducting TDS
How to rectify TDS return subsequently
Equalization Levy and compliance
TDS credit mechanism of Google and other online operators

Deductibility Of Business And Professional Expense

Deductions for business and professional expenditure
Allowable and disallowable business expenses
Depreciation and methods of calculation
Deductibility of R&D Expense

Tax On M&A And Other Business Transactions

Startup or investment tax
Capital Gains on Exits
- Short term and long-term capital gains
- Reinvestment
Carry-forward of loss in M&A transactions
Tax on Amalgamations
Tax on Partition
Accounting Standards & Taxation

Benami Transactions And Black Money Law

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015
Incentives for disclosure of black money
Punishment for black money under black money legislation and inc law
Income tax implications for black money
Money laundering vs. black money
Benami Transactions Prohibition Act , 1988 and 2016 Amendment
What is a benami asset or transaction?
Consequences of Benami Transactions
- Attachment of property
- Fine
- Imprisonment
Case study of Shahrukh Khan’s bungalow
How to challenge attachment of property

How To Comply With Tax Laws

Payment of taxes on time
- TDS
- Income Tax
- Capital gains
- Advance Tax Payment
Filing of Quarterly and Annual Returns
Tax Audits

Consequences Of Violation Of Tax Laws

Investigative powers of tax authorities
- Raids, search and seizure
- Attachment and freezing of bank accounts
- Other powers
Typical stages in tax proceedings
- Income Tax Notice
- Representation and Hearing Before Assessing Officer
- CIT (Appeals)
- ITAT
- Appeal to High Court
- Writ
- SLPs
Civil Consequences - Interest and Penalty
Criminal Consequences and imprisonment
Lookback provisions and record-keeping for tax
How tax proceedings work
Settlement process in tax litigation

International Taxation And Dtaas

Sources of International Tax Law
Does international tax law apply to you if you don’t have an office offshore?
Does international tax law apply to international payments such as Google Adwords, Amazon Web Services, etc.?
Model Tax Treaties and treaty interpretation of DTAAs under VCLT and OECD
Section 9 and Business Connection under Income Tax Act
Double Taxation Avoidance Agreements and Structure
- Permanent Establishment (in Model Agreements and DTAAs)
- Capital Gains
- Royalty
- Fee for Technical Services
- Tax Information Exchange Provisions
- Tax Credit / Refund Provisions
Permanent Establishment
- Fixed Place PE
- Agency PE
- Service PE
Withholding tax under DTAAs and Indian law
Conflict between domestic law and treaties
Impact of General Anti-Avoidance Rule (GAAR)
International Tax Issues in Secondment Arrangements

Tax Havens And Structuring

Benefits of using tax haven structures
Regulation of tax havens
Review of capital gains provision in tax-haven DTAAs
Double-Irish with a Dutch Sandwich structure
Case study - How Google, Apple, Amazon and other global corporations save billions in taxes due to cross-border structuring
Case study of tax havens:
- Mauritius for investment and financing transactions
- Singapore
- Dubai
- Cyprus
DTAA Amendments with Mauritius, Cyprus and Singapore
International tax structuring - Use of SPVs and tax havens
Vodafone Case and subsequent amendment
Consequences of Round Tripping
Double tax treaty credit systems

Advanced Issues In International Tax

Use of Holding Company Structures
How to structure a global business for tax efficiency
Place of Effective Management (POEM)
Do Commissionaire Arrangements constitute a PE?
Base Erosion and Profit Shifting (BEPS) on Advanced Tax Saving Strategies
Thin Capitalization Rules
Controlled Foreign Corporations
General Anti-Avoidance Rules (GAAR)

International Tax: Penalties & Dispute Resolution

Penalties under Indian domestic law
Tax avoidance vs. tax evasion
General Anti-Avoidance Rule (GAAR) and Special Anti-Avoidance Rule FATCA
Information exchange provisions
- International cooperation under DTAAs
- Tax Information Exchange Agreements (TIEAAs)
- Case study of Switzerland’s secrecy norms under DTAAs
How to safeguard against future risks - Authority for Advanced Rulings (AAR)
Settlement of disputes with tax authorities
Transfer pricing disputes in offshore jurisdictions

International Transfer Pricing

Why should non-tax experts know about transfer pricing?
When does transfer pricing become applicable?
Arms’ Length Pricing and methods
- Comparable uncontrolled price method (CUP)
- Resale Price Method
- Cost-Plus Method
- Transactional net Margin method(TNMM)
- Profit Split Method
How to choose an appropriate method
Role of an advanced pricing agreement (APA)
US-India APA
Associated Enterprises
Permanent Establishment
Safe Harbour Rules
Place of Effective Management
Sample Transfer Pricing Agreement

Stamp Duty

How to calculate stamp duty
Stamp duty for:
- Licensing
- Asset Purchase
- Investment Transactions
- Amalgamations
- Loan Transactions
- Security Creation: Pledge, Mortgage and Hypothecation
- Stamp duty exemptions for intra-group transactions
Consequences of insufficient or no stamping
Expiry of stamp paper
Implication of bringing an instrument into another state

Goods And Services Tax

Need of GST
Substituted taxes and surviving taxes
Types and rates of GST
Concept of ‘supply’, ‘place of supply’, ‘aggregate annual turnover’
Determination of place of supply in complex scenarios
Zero and nil-rated supply
Forward charge mechanism and reverse charge mechanism
GST Registration: Requirements, process and exceptions
Input tax credit and when it is not available
Composition scheme: Eligibility, rate of tax, compliance and advantages
TDS in GST
GST Refund
GST Returns and online filing process
Impact of GST on import and export of Goods and Services
E-way Bills
Invoice Format
Debit - Credit Note

Tax Litigation: Drafting And Filing Before Different Authorities

Tax Litigation: Drafting and Filings before the following authorities
- Assessing Officer and CIT(Appeals)
- Income Tax Appellate Tribunal
- High Court
- Settlement Commission proceedings
- Authority for Advanced Rulings
Indirect Tax Litigation - Drafting, strategy and filing work

Introduction Of Litigation Related Drafting

How to read applicable rules for tribunals, courts, and high courts
How to draft a statement of facts.
How to draft grounds of appeal
How to draft prayers

Domestic Tax Proceedings Under Income Tax Act

Basics of proceedings in Income Tax Act – AO, CIT, ITAT, HC, SLP before SC.
How to deal with proceedings before Assessment Officer – Scope and Review – Reply to Legal Notices
All about proceedings before CIT
How to compile an appeal before CIT
How to initiate and deal with proceedings before ITAT
How to draft an appeal before ITAT
All about writ petitions to be filed before High Court
How to draft a writ petition before High Court
When to file a statutory appeal and drafting a statutory appeal before the High Court.
How should you go about filing a Special Leave Petition and how should you draft it.

International Taxation And Income Tax Act

Basics about proceedings related to international taxation, transfer pricing, assessing officer / transfer pricing officer, dispute resolution panel, CIT, ITAT, HC.
All about transfer pricing officer and dispute resolution panel.
Application before competent authority – DTAA cases.

Indirect Tax Litigation

What are the different types of proceedings under the GST Act and how are these carried out?
Jurisdiction of CESTAT and how to draft and file an appeal before the CESTAT.
Indirect Tax Litigation before High Courts
How to secure a favourable ruling from Advance Authority of Ruling in GST

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