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).