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).
|Publisher||TAXMANN PUBLICATIONS PVT. LTD.|
|Publication Year||2014 EDITION|
|Number of pages||1572|