remove Double taxation Structure of a typical DTAA and major Models Conventions used in world Applicability of DTAA Interpretation techniques of DTAA How to determine which DTAA is applicable and how to apply that DTAA Some important concepts used in DTAA Some important points to remember 3 Problems faced while uploading • Form 15CA • • • CA Dayavanti Khilolani 28th January 2012 CA Dayavanti Khilolani 28th January 2012 4 Tax Payer resident of
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DTAT | 4.1.Types of relief: Relief from double taxation can be provided mainly in two ways (i) Bilateral relief (ii) Unilateral relief. (i) Bilateral relief: Under this method, the Governments of two countries can enter into an agreement to provide relief against double taxation by mutually working out the basis on which relief is to be granted. India has entered into agreement for relief against or avoidance of double taxation with 77 countries up to May,2010. Bilateral relief may be granted
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for tax evasion and to what extent the measures that are being taken by the Government to combat this bad publicity are effective. The specific objectives of this study are: To understand the purpose and functioning of treaty arrangements Mauritius has with other countries throughout the world. To test the effectiveness of the measures to combat tax evasion. To test the knowledge of employees in the global business sector. Research questions To what extent employees understand the tax regime
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The German tax authorities The „Bundeszentralamt für Steuern“ (The Federal Central Tax Office) is responsible for the tax system in Germany. In order to catch tax evaders the German authorities have ample access privileges. In the case of suspicion of tax evasion they have access to most public databases. Moreover in Germany the bank secrecy in fact doesn’t exist since the banks have to corporate with the tax authorities, if there is any suspicion of tax evasion. Punishment for tax evasion is
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1.0 Introduction From the Malaysian perspective, to begin with, there must first be a tax liability under the Malaysian Income Tax Act, 1967 (ITA). Once this is established, then one has to check the provisions in the DTA to see whether a reduction of tax rate or total elimination is available. If so, the DTA must be respected. This is clearly provided in the ITA, namely S 132(1) which states that if the Minister by statutory order declares that arrangements set out in such order been made by the
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MT570 Taxation (Current Topics) Assignment 2 Question 1 The draft tax determination TD 2009/18 – Income Tax: Can a private equity entity make an income gain from the disposal of target assets it has acquired? – deals with private equity entities disposing of Australian target assets, and per this draft determination, the ATO’s view on this is that yes a private equity entity can make an income gain on the disposal of such assets, although they do acknowledge that each case will depend on
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Major areas for final settlement of tax liability : Tax deducted at source for the following cases is treated as final discharge of tax liabilities. No additional tax is charged or refund is allowed in the following cases:- * Supply or contract work * Band rolls of hand made cigarettes * Import of goods * Transfer of properties * Export of manpower * Real Estate Business * Export value of certain items including knit and woven garments. * Local shipping business * Royalty
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Income Tax Treaties in International Taxation Tax treaties are bilateral agreements between countries. The purpose of bilateral tax treaties is typically expressed to be “the avoidance of double taxation and the prevention of fiscal evasion.” As most countries contain within their domestic law provisions to prevent double taxation of their residents where another country taxes the same income on a source basis, the main operation of tax treaties in this respect is for other types of double taxation
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its overall tax burden. One such strategy is discussed in this paper. Transfer pricing allows the company to price the inter-company transactions. Transfer pricing simplifies the accounting of transactions that take place between affiliated or related entities. Companies have freedom in valuing inter-company transactions. But, if strategically implemented, this strategy allows the company to save taxes and retain large amount of profits. Keywords: Transfer mispricing, tax-havens, Double Irish Dutch
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Double Taxation Avoidance Agreement - India & Mauritius: Does revising treaty loosen up the existing relations? The island Mauritius located in the south west part of the Indian Ocean lies about 3,900kms south west of India. Despite the long distance separation between the countries, Mauritius still possesses the seeds of Indian origin sown back in 1820’s during the time of colonial rule. According to the statistical data, 68% of the Mauritians are Indian origins called as ‘Indo – Mauritians’
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