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Description A Comprehensive and authentic Commentary on Indian Double Taxation Agreements with the help of decisions of International & Indian Courts as well as Authority for Advance Rulings A comprehensive & critical study of UN Model Convention • Comparative and critical analysis of OECD Model Convention • Doing business with or in India, including e-business • Genesis and development of Treaty Models • Supremacy of a Tax Treaty over the domestic laws • Interpretation of a Tax Treaty • Classification of Income • Scope and purpose of a Tax Treaty • Taxes covered by a Treaty • Explaining definitions and expressions used in a tax treaty such as 'Resident', ' Permanent establishment', and others including Transfer pricing', 'Arm's length transactions', Treaty Shopping', etc. • Explaining expressions used in domestic tax laws but not defined in tax treaties such as Income (Real Income, Fictional Income, Substance over form). Total Income, Business, Profession, Computation of Income, etc. • Computation of income and distributive rules relating to income from Business, Shipping Business, Associated Enterprises, Capital Gains, Investment Income (dividends, interest, and royalties), Income from activities (personal and impersonal, pensions, directors' fee, entertainment, athletes, sports), Remuneration to students, etc. • Non-discrimination • Mutual agreement procedure for resolving disputes • Methods of eliminating Double Taxation, including Tax Sparing • Text of Double Taxation Agreements and Compendium of Relevant Circulars • Compendium of Rulings of Authority for Advance Rulings ............................................................................................................................. Contents Volume 1 1. Double Taxation Agreement - Doing Business in or with India 2. Double Taxation Agreement - Genesis 3. Double Taxation Agreement and Domestic Law 4. Double Taxation Agreement - Interpretation 5. Double Taxation Agreement - Classification and Qualification of Income 6. Double Taxation Agreement - Preamble 7. Double Taxation Agreement - Personal Scope 8. Double Taxation Agreement - Taxes Covered 9. Double Taxation Agreement - Definitions 10. Double Taxation Agreement - Resident 11. Double Taxation Agreement - Permanent Establishment 12. Double Taxation Agreement - Income from Immovable Property 13. Double Taxation Agreement - Taxation of Business Profits 14. Business Income - Shipping, Inland Waterways and Air Transport 15. Double Taxation Agreement - Associated Enterprises 16. Double Taxation Agreement - Dividends 17. Double Taxation Agreement - Interest 18. Double Taxation Agreement - Royalties 19. Double Taxation Agreement - Capital Gains 20. Double Taxation Agreement - Independent Personal Service 21. Double Taxation Agreement - dependent Personal Service 22. Double Taxation Agreement - Director’s Fees 23. Double Taxation Agreement - Artistes and Sports Persons 24. Double Taxation Agreement - Pensions and Social Security Payments Volume 2 25. Double Taxation Agreement - Government Service (Remuneration and Pension) 26. Double Taxation Agreement - Students and Apprentices 27. Double Taxation Agreement - Other Income 28. Double Taxation Agreement - Capital 29. Double Taxation Agreement - Elimination of Double Taxation 30. Double Taxation Agreement - Non - Discrimination 31. Double Taxation Agreement - Mutual Agreement Procedure 32. Double Taxation Agreement - Exchange of Information 33. Double Taxation Agreement - Diplomatic Agents 34. Double Taxation Agreement - Ratification and Termination 35. Income - General Concepts 36. Income - Doctrine of Real Income 37. Income - Fictional Income 38. Income - Substance of the Transaction 39. Income - Chargeability 40. Total Income - Scope 41. Total Income - Computed in the Manner Laid Down in the Act 42. Total Income - Computation (Deductions) 43. Income - Classification 44. Income - Quantification 45. Profits and Gains of Business 46. Income - Capital or Revenue 47. Profits and Gains - Expenditure and Loss 48. Income - Keyman Insurance 49. Income - Aggregation 50. Income Computation - Accounting Standards 51. Income Computation - Accounting Standard -1 52. Income Computation - Accounting Standard - 2 53. Transfer Pricing Annexures Volume 3 Relevant Circulars & Clarifications • Specific Provisions made in Double Taxation Avoidance Agreement-Whether it would Prevail over General Provisions Contained in Income-Tax Act • Non-Discrimination Article under the Double Taxation Avoidance Agreements (DTAA) • Agreement for Avoidance of Double Taxation with Pakistan - Whether Operative Assessment Year 1972-73 and SubsequentAssessment Years • Clarification Regarding the Applicability of the Double Taxation Avoidance Agreement with the People's Republic of China to Hong Kong • Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Kenya • Clarification Regarding Taxation of Income from Dividends and Capital Gains under the Indo-Mauritius Double Tax Avoidance Convention (DTAC) • Indo-Us Double Taxation Avoidance Agreement (DTAA)-Suspension of Collection During Mutual Agreement Procedure (MAP) • Indo-Us Double Taxation Avoidance Convention (DTAC)-Suspension of Collection During Mutual Agreement Procedure • India-UK Double Taxation Avoidance Agreement (DTAA)-Suspension of Collection of Taxes During Mutual Agreement Procedure • Income-Tax (Double Taxation Relief) (Dominions) Rules, 1956 Providing for Grant of Double Taxation Relief with certain Dominions - Present Position There under • Income-Tax (Double Taxation Relief) (Aden) Rules, 1953 -Present Position There under • Mutual Agreement Procedure for Double Taxation A Voidance Convention Procedure • Expression "Indian Rate of Tax" In Clause (II) of Explanation to the Section - Interpretation of • Admissibility of Relief under the Section in the case of Partner in Respect of his Proportionate Share of Tax Paid by Firm in Foreign Country on its Income which Accrued or Arose During Previous Year Outside India • Application of Provision to Sikkim Prior to 1-4-1990 • Clarification on Provisions Governing Transfer Price in an International Transaction • Transfer Pricing Officer - Notified Subordinate Officer • Transfer Pricing- Computation of Income from International Transaction having Regard to Arm's Length Price under Section 92 • Reference to Transfer Pricing Officer and his Role Comprehensive Agreements - with Respect to Taxes on Income • Armenia • Australia • Austria • Bangladesh • Belarus • Belgium • Brazil • Bulgaria • Canada • China • Cyprus • Czech Republic • Denmark • Egypt • Finland • France • Germany • Greece • Hungary • Indonesia • Ireland • Israel • Italy • Japan • Jordan • Kazakstan • Kenya • Korea • Kuwait • Kyrgyz Republic • Libya • Malaysia • Malta • Mauritius • Mongolia • Morocco • Namibia • Nepal • Netherlands • New Zealand • Norway • Oman • Philippines • Poland • Portuguese Republic • Qatar • Romania • Russia • Saudi Arabia • Singapore • Slovenia • South Africa • Spain • Sri Lanka • Sudan • Sweden • Swiss Confederation • Syria • Tanzania • Thailand • Trinidad And Tobago • Turkey • Turkmenistan • UAE • UAR (Egypt) • USA • UK • Uganda • Ukraine • Uzbekistan • Vietnam • Zambia Limited Agreements - With Respect to Income of Airlines /Merchant Shipping • Afghanistan • Bulgaria • Czechoslovakia • Ethiopia • Iran • Kuwait • Lebanon • Oman • Pakistan • Russian Federation • Saudi Arabia • Switzerland • UAE • Yemen Arab Republic • People's Democratic Republic of Yemen Other Agreements/ Double Taxation Relief Rules • African National Congress Mission • Income-Tax (Double Taxation Relief) (Dominions) Rules, 1956 Providing for Grant of Double Taxation Relief with certain Dominions • Income-Tax (Double Taxation Relief) (Aden) Rules, 1953 Unilateral Double Taxation Relief • Expression "Indian Rate of Tax" in Clause (it) of Explanation to the Section - Interpretation of • Admissibility of Relief under the Section in the case of Partner inrespect of his Proportionate Share of Tax Paid by Firm in Foreign Country on its Income which Accrued or Arose During Previous Year Outside India ............................................................................................................................. Author Details D.P. Mittal is an advocate, tax and business law consultant. He has a long experience in administering tax laws as an officer of Indian revenues, and in advising investors and entrepreneurs on legal aspects of investments in India as an advocate now and previously as a senior adviser in the Indian Investment Centre, New Delhi (a Government of India Organisation). .............................................................................................................................
