Become the next MLI Mastermind - Course
- Year of Publication: 2020
- ISBN: 0
Course Duration:
980 minutes comprising of 6 episodes
Course Background:
As American author, Ted Dekker puts it “The power of belief alone could change the course of history”. As so it goes with OECD’s ambitious & grandiose BEPS project, particularly Action Plan 15 [which deals with the implementation of MLI], that in one pen stroke has the unique ability to amend around 1500 bilateral tax treaties. While the MLI for decades to come could form the basis for building a global consensus for international fiscal rules, eliminating double taxation and double non-taxation, and creating a new and efficient mechanism to resolve disputes, however, one of its key attractions is also probably its greatest weakness. The flexibility afforded to participated jurisdictions in terms of making reservations, opt-outs and the different options available to implement the BEPS minimum standards actually create a web of additional complexity and confusion.
Closer home, India ratified the MLI and deposited the instrument on June 25, 2019, in which, tax treaties with 93 countries had been included as “Covered Tax Agreements”. Furthermore, India’s MLI took effect from 1st April 2020 for the first set of 23 DTAAs with other countries, including Singapore, Japan and the United Kingdom [who have deposited their instruments of ratification before June 30, 2019]. Also, it is worth noting that 7 other countries including Canada, Denmark have deposited their instruments of ratification after June 30th but before December 31st, thereby triggering the 'entry into effect' for withholding taxes w.e.f. April 1st.
What shall the course cover?
Against this backdrop, Taxsutra is delighted to bring to you a one-of-a-kind 6 episode Master-Class Series on “MLI Mastermind” with Three Renowned International Tax Experts, Tax Advocate Mukesh Butani (Founder, BMR Legal), Mr. Padamchand Khincha (Chartered Accountant) & Senior Advocate K.K.Chythanya. The Master-Class Series has thoroughly dissected each and every aspect of MLI, including the following:
|
Part |
Broad Topic Coverage |
Sub-Topics |
Stalwart/s |
|
I |
Setting the Context |
Introduction & Basic Overview of MLI |
Tax Advocate Mukesh Butani |
|
II |
Article by Article Dissection of MLI while closely analyzing, (i) India’s Position, (ii)Effect on CTAs & (iii) Case Studies, for each Article, discussed in the series respectively
|
Articles 3 to 5 (Transparent Entities, Dual Resident Entities & Application of methods for elimination of double taxation)
|
Mr. Padamchand Khincha & Senior Advocate K.K.Chythanya |
|
III |
Articles 6 & 7 (Purpose of CTA & Prevention of Treaty Abuse) |
||
|
IV |
Articles 10, 12 & 15 (Anti-Abuse rule for PE situated in third jurisdictions, Artificial avoidance of PE through Commissionaire and similar arrangements & Definition of a person “closely related” to an enterprise) |
||
|
V |
Articles 13 & 14 (Artificial avoidance of PE status by the exemption of specific activity & Splitting up of contracts) |
||
|
VI |
Articles 8, 9 & 11 (Dividend Transfer-Transactions, Capital Gains & Application of tax agreements to restrict a party's right to tax its own residents) |
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
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Overall Rating
- Year of Publication: 2020
- ISBN: 0
Course Duration:
980 minutes comprising of 6 episodes
Course Background:
As American author, Ted Dekker puts it “The power of belief alone could change the course of history”. As so it goes with OECD’s ambitious & grandiose BEPS project, particularly Action Plan 15 [which deals with the implementation of MLI], that in one pen stroke has the unique ability to amend around 1500 bilateral tax treaties. While the MLI for decades to come could form the basis for building a global consensus for international fiscal rules, eliminating double taxation and double non-taxation, and creating a new and efficient mechanism to resolve disputes, however, one of its key attractions is also probably its greatest weakness. The flexibility afforded to participated jurisdictions in terms of making reservations, opt-outs and the different options available to implement the BEPS minimum standards actually create a web of additional complexity and confusion.
Closer home, India ratified the MLI and deposited the instrument on June 25, 2019, in which, tax treaties with 93 countries had been included as “Covered Tax Agreements”. Furthermore, India’s MLI took effect from 1st April 2020 for the first set of 23 DTAAs with other countries, including Singapore, Japan and the United Kingdom [who have deposited their instruments of ratification before June 30, 2019]. Also, it is worth noting that 7 other countries including Canada, Denmark have deposited their instruments of ratification after June 30th but before December 31st, thereby triggering the 'entry into effect' for withholding taxes w.e.f. April 1st.
What shall the course cover?
Against this backdrop, Taxsutra is delighted to bring to you a one-of-a-kind 6 episode Master-Class Series on “MLI Mastermind” with Three Renowned International Tax Experts, Tax Advocate Mukesh Butani (Founder, BMR Legal), Mr. Padamchand Khincha (Chartered Accountant) & Senior Advocate K.K.Chythanya. The Master-Class Series has thoroughly dissected each and every aspect of MLI, including the following:
|
Part |
Broad Topic Coverage |
Sub-Topics |
Stalwart/s |
|
I |
Setting the Context |
Introduction & Basic Overview of MLI |
Tax Advocate Mukesh Butani |
|
II |
Article by Article Dissection of MLI while closely analyzing, (i) India’s Position, (ii)Effect on CTAs & (iii) Case Studies, for each Article, discussed in the series respectively
|
Articles 3 to 5 (Transparent Entities, Dual Resident Entities & Application of methods for elimination of double taxation)
|
Mr. Padamchand Khincha & Senior Advocate K.K.Chythanya |
|
III |
Articles 6 & 7 (Purpose of CTA & Prevention of Treaty Abuse) |
||
|
IV |
Articles 10, 12 & 15 (Anti-Abuse rule for PE situated in third jurisdictions, Artificial avoidance of PE through Commissionaire and similar arrangements & Definition of a person “closely related” to an enterprise) |
||
|
V |
Articles 13 & 14 (Artificial avoidance of PE status by the exemption of specific activity & Splitting up of contracts) |
||
|
VI |
Articles 8, 9 & 11 (Dividend Transfer-Transactions, Capital Gains & Application of tax agreements to restrict a party's right to tax its own residents) |
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
