Taxmanns International Taxation Ready Reckoner [Finance Act 2025] Comprehensively Covers Indias Crossborder Tax FrameworkO
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Description
International Taxation Ready Reckoner presents a lucid, allencompassing reference for readers. Authored by two leading experts in the fieldthis book incorporates the latest amendments brought about by the Finance Act 2025. It simplifies complex crossborder tax concepts, guiding readers through intricate regulations, bilateral tax treaties, and procedural requirements. With practical examples, case studies, and uptodate judicial precedents, this Ready Reckoner ensures that readers can advise and comply with Indias everevolving international tax landscape.This book is intended for the following audience: Tax & Legal Professionals Chartered Accountants, tax consultants, legal advisors, and inhouse counsels who deal with international taxation and crossborder transactions Corporate Executives & Finance Teams CFOs, finance managers, and corporate tax departments responsible for ensuring tax compliance, structuring overseas investments, and evaluating crossborder business arrangements Academics & Students Faculty, researchers, and advanced students specialising in international taxation, seeking practical insights and practical applications Entrepreneurs & SMEs Business owners expanding internationally who need a straightforward, professional reference to navigate Indias international tax provisionsThe Present Publication is the 3rd Edition, amended by the Finance Act 2025. This book has been authored by CA. Daksha Baxi & Adv. Surajkumar Shetty, with the following noteworthy features: [Amended by the Finance Act 2025] Incorporates all legislative updates effective from the latest Finance Act, ensuring readers remain current with recent changes [Authoritative Guidance] Written by highly acclaimed tax experts recognised by global legal rankings [Practical Insights & Case Studies] Illustrates practical transactions and solutions, culminating in a comprehensive case study applying the rules and concepts explained [Stepbystep Explanations] Offers clarity on understanding the interplay between the Indian Incometax Act 1961, Double Taxation Avoidance Agreements (DTAAs), and OECD/UN model conventions [Useful Tools & Aids] Contains ready reckoners, tabular comparisons, and examples to simplify complex topics like Permanent Establishment, Transfer Pricing, GAAR, etc. [Latest Judicial Precedents] Indepth discussion of landmark Indian and international rulings, enabling readers to strategise with the most recent case laws [Practical Compliance Checklist] Guides readers on obtaining a Permanent Account Number (PAN), Withholding Tax (TDS) compliance, return filing, Transfer Pricing documentation, and other procedural mandatesThe coverage of the book is as follows: Foundational Conceptso Residential status determination (individuals, corporates, other entities)o Scope of income and deemed accrual principles Treaty Analysiso Key DTAA articles and interpretationo Most Favoured Nation (MFN) clauses, tiebreaker rules, and OECD/UN model commentary Setting Up in Indiao Business structures: subsidiaries, liaison offices, branch officeso Valuation provisions, antiavoidance measures on share premium Taxation of Various Income Streamso Business income (Permanent Establishment, attribution of profits)o Dividend, interest, royalty, and fees for technical serviceso Capital gains, including indirect transfer of Indian assetso Employment income (including ESOPs for globally mobile employees)o Special regimes for NRIs, Foreign Portfolio Investors (FPIs), AIFs, REITs, InvITs, etc. Transfer Pricing Regulationso Arms length price determination methods, safe harbour rules, Advance Pricing Agreements (APAs), secondary adjustments Business Reorganisations & Exitso Taxneutral amalgamation, demerger conditions, liquidation aspects, setoff and carryforward of losses Dispute Resolution & Complianceo Assessments, appeals, DRP, Mutual Agreement Procedure (MAP), Authority for Advance Rulings (AAR)o GAAR provisions, how and when they applyo Withholding tax obligations, TDS/TCS rates, payment procedures Case Studyo An extensive, endtoend illustration combining multiple crossborder tax scenarios, from structuring to complianceThe structure of the book is as follows: Logical Progression Starts with fundamental concepts of residency and the broad framework of international taxation, then progresses through specific income types, compliance measures, and dispute resolution avenues Chapterwise Explanation Each chapter addresses a distinct segmente.g., Taxation of Dividends, Taxation of Royalties, Transfer Pricing, etc.allowing readers to locate relevant material instantly Practiceoriented Approach Every chapter includes practical examples, references to judicial rulings, and frequently encountered Q&A Dedicated Case Study Concludes with a comprehensive scenario tying all concepts together, serving as a blueprint for realworld advisory and compliance scenarios Appendices Relevant forms, statutory
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