Elective Paper- 6C- NOV 19 CA AARISH KHAN AJ Education NeXt

PREFACE

It is my great pleasure to present this super small summary containing all list of Sections,
Rules, Articles , Circulars and other relevant factors for Elective Paper 6C- International
Taxation.

The most salient feature of this summary is mention of precise Page numbers of every
provision as per STUDY MATERIAL OF ICAI which may help a student to save his/ her
valuable time during the exam.

This is something which was there in my mind since day one when Elective Paper was
announced by ICAI and I have tried my best to make it as useful as possible for all my
dearest students.

WE ARE FIRST IN INDIA TO INNOVATE SUCH THINGS FOR ELECTIVE PAPER NOV 2018 AND
CONTINUING IT FOR MAY/ NOV 2019 & NOW FOR MAY/ NOV 2020. YOU WILL FIND THAT
SUMMARY IN BOOK 2.

I hope this may help you all. Kindly share your feedback.

In case of any errors or omission kindly forgive for the same.

ALL THE BEST,

GOD BLESS YOU ALL.

CA AARISH KHAN.

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Elective Paper- 6C- NOV 19 CA AARISH KHAN AJ Education NeXt

ELECTIVE PAPER 6C - INTERNATIONAL TAXATION SYNOPSIS

WITH PAGE NUMBERS:

Sr Particulars Section/ Rules/ PAGE NO AS
No. Article, if any PER SM
CHAPTER 1 : TRANSFER PRICING

1 What is Transfer Pricing ? - 1.4
2 Meaning of Arms Length Price ? - 1.4
3 Significance of Arms Length Principle. - 1.5
4 Practical Difficulties in Application of ALP - 1.6
5 Evolution of Transfer Pricing in India - 1.7
6 Charging Section of Transfer Pricing: 92 1.10
When Transfer pricing not applicable ? 92(3) 1.11
7 Associated Enterprises ( 13 Cases ) 92A 1.11 to 1.16
8 Definition of International Transaction & Deemed 92B(1)/(2) 1.16
International Transactions 1.16
9 Specified Domestic Transaction 92BA 1.21
( For Detail Refer Regular Course Book )
10 Computation of ALP 92C 1.22
1. METHODS OF ALP: Rule 10B(1)
a. CUP Method 1.24
b. RSP method 1.26
c. Cost Plus Method 1.27
d. Profit Split Method ( 2 Methods in this ) 1.28
e. Transactional Net Margin Method 1.30
f. Other Method as prescribed by CBDT 1.31

2. Selection of Tested Party 1.33
3. Selection of PLI 1.33
4. Most Appropriated Method 1.34
5. RANGE CONCEPT Rule 10CA 1.35
(Better you refer Regular course Book )
6. RANGE CONCEPT Non Applicability Rule 10CA 1.39
11 Functions, Assets & Risk Analysis - 1.40
12 Concept of Comparability Adjustments - 1.44
13 Information & Documents to be Maintained 92D & Rule 1.45 to 1.52
10D(1)(2)(3)
14 Audit Report ( Form 3CEB ) 92E 1.53
15 Penalties in Transfer Pricing:
a. Misreporting 200%. 270A(6)(9) 1.53
b. Failure to Keep & Maintain Information & 271AA 1.53
Documents.
c. Failure to furnish Information & 271G 1.54
Documents to AO & CIT(A) within 30 days.

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Elective Paper- 6C- NOV 19 CA AARISH KHAN AJ Education NeXt

d. Failure to Furnish Report u/s 92E. 271BA 1.54

16 a. Country by Country Reporting 286/ 1.56 to 1.57
b. Penalties 271GB/ 1.58
273B 1.58
c. Submission of Master File Rule 10DA 1.58 to 1.61
17 Assessment by Assessing Officer 92C(3)/(4) 1.64
18 Reference to Transfer Pricing Officer 92CA 1.65
19 Secondary Adjustment 92CE & 1.67
Its Rules Rule 10CB(1) 1.68
&(2) 1.68 & 1.69

20 Dispute Resolution mechanism 144C 1.69
21 Appeal to CIT (A) 246A, 249 & 250 1.71
Difference between CIT(A) & DRP 1.72
22 Appeal to ITAT 253 & 254 1.73
23 Appeal to High Court & Supreme Court 260A/261/262 1.73 &1.74
24 SAFE HARBOUR RULES : Sec 92CB
a. Provision of Software Development 1.75
Services
b. Provision of Information Technology 1.75
enabled Services
c. Provision of knowledge process 1.76
outsourcing services
d. Advancing of Intra Group Loans where 1.77
amt is denominated in INR
e. Advancing of Intra Group Loans where 1.77 & 1.78
amt is denominated in Foreign Currency
f. Providing Corporate Guarantee 1.78
g. Provision of contract R & D services wholly 1.79
or partly relating to software
development
h. Provision of contract R & D services wholly 1.80
or partly relating to generic
pharmaceutical drugs
i. Manufacture and export of core auto 1.80
components
j. Manufacture and export of Non core auto 1.80
components
k. Receipt of Low Value adding intra group 1.81
services from one or more members of its
group

Definition of certain terms in Safe Harbour 1.82- 1.85
Procedure to be followed in Safe Harbour Rule 10TE & 1.85 to 1.87
Rules Form 3CEFA

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25 Advance Pricing Agreement : 92CC 1.88

a. Rules of APA Rule 10G to 10T 1.89
b. Roll Back Provision 10F/10MA/10RA 1.93
c. CBDT 14 FAQ’s on APA 10/2015 1.95 to 1.100
d. Effect of APA 92CD 1.100
26 Mutual Agreement Procedure Rule 44G & 44H 1.101

27 Transfer of Income to Non Resident 93 1.105

28 Notified Jurisdictional Area ( Cyprus Notification ) 94A 1.107

29 Limitation of Interest Deduction 94B 1.110

CHAPTER 2: NON RESIDENT TAXATION:

30 Assessee 2(7) 2.2

31 Person 2(31) 2.3

32 A.Y 2(9) 2.3

33 P.Y 2(34) r.w. 3 2.3

34 Domestic Company 2(22A) 2.3

35 Foreign Company 2(23A) 2.4

36 India 2(25A) 2.4

37 Resident 2(42) 2.4

38 Non Resident 2(30) 2.4

39 Transfer 2(47) 2.4

40 Charging Section of Income Tax ( Tax Rates of 4 2.5

Foreign Companies )
41 Residential Status of Individual 6 2.6

Crew Member of a Foreign Bound Ship Rule 126 2.7 / 2.8
& CBDT Circular
42 Residential Status of HUF/Firm/ AOP or BOI, Local 6 2.9
Authority and Artificial Juridical Person

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43 Residential Status of a Company and the Concept 6(3) 2.10- 2.20

of POEM:
a. Active Business Outside India 2.10
b. Not Engaged in Active Business outside 2.12
India
c. Other Guiding Principles 2.14
d. Examples on POEM 2.18

Transition Mechanism : 115JH 2.20
Notification for sec 115JH 29/2018 2.21 to 2.25
44 Scope of Total Income: 5
Clarification for NR Seafarer’s 13 & 17/2017 2.28
Meaning of “ Income received or deemed to be 2.28
received “ &
Meaning of “Income Accrued & Arising “ 2.29

45 Meaning of “ Income deemed to accrue or arise 9 2.29- 2.42
“:
a. Business Connection 2.31 to 2.34
( 2 FA 2018 Amendments)
b. Income from Property , asset or source of 2.34
income in India
c. Income through transfer of Capital Asset 2.34
d. Vodafone Case Law (Do from Regular 2.34
Book and what we wrote in class )
e. Income from Salaries earned in India 2.38
f. Income from Salaries payable by the 2.38
Government for services rendered outside
India & Allowances u/s 10(7)
g. Dividend paid by an Indian Company 2.38
outside India
h. Interest (Explanation for Banking 2.38 & 2.39
Company)
i. Royalty (Exception of TDS u/s 194J) 2.39
3 Explanations
j. Fees for Technical Services 2.42

46 Eligible Fund Manager Exempted from Business 9A 2.42 to 2.46
Connection
47 Exemptions u/s 10 10 2.46 to 2.52

48 PRESUMPTIVE INCOMES :
a. NR Shipping Business 44B vs 172 2.53
b. NR Exploration of Minerals Business 44BB 2.56
( Also Refer 115A & 44DA )
c. NR Operation of Aircraft Business 44BBA 2.57
d. FOREIGN COMPANY business of Civil 44BBB 2.58

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Construction, Turnkey Project

e. Head Office expense allocation for NR 44C 2.59
f. Royalty etc of Non Resident where PE is 44DA 2.61
located in India ( Also Refer 115A )
49 Capital Asset 2(14) 2.63

50 Short Term & Long Term Capital Asset 2(42A) & 2.66
2(29A)
51 EXEMPT TRANSFERS: 47 2.67 to 2.69
a. Transfer of Indian Company shares in 47(via)
Foreign Amalgamation
b. Transfer of Foreign Company Shares in 47(viab)
Foreign Amalgamation ( See Vodafone
Case)
c. Transfer of Indian Company shares in 47(vic)
Foreign Demerger
d. Transfer of Foreign Company Shares in 47(vicc)
Foreign Demerger ( See Vodafone Case)
e. Transfer of Bond or GDR by NR to NR 47(viia)
f. Transfer of Rupee Denominated Bonds of 47(viiaa)
Indian Company by NR to NR
g. Transfer of Specified asset by NR on a RSE 47(viiab)
located in IFSC ( FA 2018)
h. Transfer of Govt securities by NR to NR 47(viib)

52 Mode of Computation of Capital Gains 48 2.69
Note:
a. STT not allowed as deduction
b. INDEXATION CHART 2.70
53 NR investing in Shares and Debentures of Indian First Proviso to 2.70
Company 48 & Rule 115A
Note:
50C/50CA/50D & 2.72
4th Proviso to sec 2.74
48
54 Cost of Acquisition in Certain cases, i.e. cases of 49(1) 2.74 to 2.76
Previous Owner
55 STCG Tax on Equity shares / Equity Oriented 111A 2.76
Funds/ Units of Business Trust

55A LTCG Tax on Equity shares / Equity Oriented 112A & 2.78 to 2.85
Funds/ Units of Business Trust (FA 2018) N/N-60/2018

56 Tax on LTCG 112 2.77

57 Special Provisions for NRI CH XII-A 2.85 to 2.89

115C to 115I

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58 Special tax Rates:

a. Tax on Dividend & Interest of NR & 115A 2.90
Foreign Company
b. Tax on Royalty & Fees for Technical 115A 2.91
Services of NR & Foreign Company
c. Tax on Mutual Funds Investment by OFO 115AB 2.91
d. Tax on Bonds or GDR purchased by NR &
Foreign Company 115AC 2.92
e. Tax on FII’s from securities 115AD 2.94
f. Tax on NR Sportsmen or Sports 115BBA 2.95
Association

59 Applicability of MAT on Foreign Companies Explanation 4 to 2.98
115JB
Non Applicability of MAT to Sec Explanation 4Ato 2.99
44B/44BB/44BBA/44BBB ( FA 2018 ) 115JB

60 Conversion of Indian Branch of Foreign Bank in to 115JG 2.100
Indian Subsidiary
61 TDS on Salary 192 2.101

62 TDS on Lottery etc 194B & 194BB 2.101

63 TDS on payment to NR Sportsmen or Sports 194E 2.102

Association

63A TDS on Commission on sale of lottery 194G 2.103
64 TDS on Income by way of Interest from 194LB 2.103
Infrastructure Debt Fund to Non Resident
65 TDS on Income from Units of a Business Trust to 194LBA 2.104
Non Resident
66 TDS on Income of Units of Investment to Non 194LBB 2.104
Resident Unit Holders
67 TDS on Income in respect of Investment made in a 194LBC 2.105
Securitization Trust
68 TDS on Income by way of Interest from Indian 194LC 2.106
Company
69 TDS on Interest on Govt Securities or Rupee 194LD 2.107
Denominated Bonds of an Indian Company
payable to FII’s or QFI’s
70 TDS on Payment of any other sum to Non 195 2.107
Resident:
a. Payer may be Resident or Non 2.108
Resident.
b. Time of Deduction. 2.108
c. Payments subject to Tax Deduction. 2.108
d. Certificate of Non Deduction. 2.109

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Elective Paper- 6C- NOV 19 CA AARISH KHAN AJ Education NeXt

e. Deductor to Furnish prescribed 2.109

information.
f. Making application to AO to determine 2.109
appropriate proportion of sum
chargeable to tax.
g. Procedure for Refund of TDS u/s 195 2.110
to the person deducting tax in cases
where tax is deducted at a higher rate
prescribed in DTAA.

71 Income payable net of tax 195A 2.110

72 Income from Units 196B 2.111

73 Income from Foreign Currency Bonds or shares of 196C 2.111

Indian Company
74 Income of Foreign Institutional Investors from 196D 2.111
Securities
75 Certificate for deduction of tax at a lower rates 197 2.111

76 Credit for Tax at source 199 2.112

77 Mandatory requirement of furnishing PAN in all 206AA 2.113

TDS, bills, voucher and correspondence between
the deductor and deductee:
a. Non applicability of sec 206AA to Non 2.113
Residents.

78 MISCELLANEOUS PROVISIONS:
a. Furnishing of Return of Income 139(1) 2.115
b. Who is regarded as Representative 160 2.116
Assessee ?
c. Who may be regarded as Agent ? 163 2.116
d. Liability of Representative Assessee . 161 2.117
e. Rights of representative assesse to recover 162 2.117
tax paid
f. Direct assessment or recovery not barred 166 2.118
g. Remedies against property in cases of 167 2.118
representative assesse
h. Recovery of tax in respect of NR from his 173 2.118
assets
i. Recovery against the assessee’s property 228A 2.118
in foreign countries
j. Submission of statement by a non resident 285 2.119
having liaison office
k. Furnishing of Information or documents 285A 2.119
by an Indian Concern

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CHAPTER 3: DOUBLE TAXATION RELIEF

79 a. Bilateral Relief 90/90A 3.2
( See 5 Illustrations ) 3.5
b. Unilateral Relief 91 3.12
( See Illustrations ) 3.13
c. Taxation of BPO Circular 5/2004 3.20

CHAPTER 4 : ADVANCE RULINGS

80 a. Definition of Advance Ruling 245N(a) 4.2
b. Applicants 245N(b)(A) 4.2
c. Authority of Advance Ruling 245-O 4.3
d. Qualifications, terms and conditions of 245-OA 4.5
service of Chairman, vice chairman and
members
e. Vacancies etc not to invalidate 245P 4.5
proceedings
f. Application for Advance Ruling 245Q 4.6
g. Procedure on receipt of Application 245R 4.7
( Important Illustration)
h. Applicability of Advance Ruling 245S 4.9
i. Advance Ruling to be void in certain cases 245T 4.10
j. Powers of the Authority 245U 4.11
k. Procedure of Authority 245V 4.11

CHAPTER 5 : OVERVIEW OF THE BLACK
MONEY LAW & IMPOSITION OF TAX LAW

81 Charging section 3 5.2

82 Undisclosed Foreign Income & asset 2(12) 5.2

83 Undisclosed asset located outside India 2(11) 5.2

84 Assessee 2(2) 5.2

85 Previous Year 2(9) 5.3

86 Relevant Previous year of chargeability Proviso to sec 5.3

3(1)
87 Valuation of Undisclosed asset & its RULES of Sec 3(2) 5.4 to 5.7
Valuation & Rule 3(1)

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88 FMV of an asset ( other than bank account ) Rule 3(2) 5.8

transferred before valuation date
89 FMV in a case where a new asset is acquired out Rule 3(3) 5.8
of consideration received on account of transfer
of an old asset or withdrawal from a Bank account
( See Example )
90 Rate of conversion of currency used to used to Rule 3(4) & 3(5) 5.8
determine FMV of an asset
91 Relevant Date for determination of market value Explanation 2 to 5.9
and conversion of currency Rule 3
92 Scope of Total Undisclosed Foreign Income and 4 5.10
asset
93 Computation of Total Undisclosed Foreign Income 5 5.11
and asset ( See Example )
94 Tax Authorities 6 5.11

95 Change of Incumbent 7 5.12

96 Powers of Discovery and Production of Evidence 8 5.12

97 Proceeding before tax authorities to be judicial 9 5.13

proceedings
98 Assessment 10 5.14

99 Time Limit to complete Assessment 11 5.15

100 Rectification of Mistake 12 5.16

101 Notice of Demand 13 5.16

102 No Bar on Direct Assessment or Recovery 14 5.17

103 Appeal to Commissioner 15 5.17

104 Appeal to Tribunal 18 5.18

105 Appeal to High Court 19 5.19

106 Appeal to Supreme Court 21 5.19

107 Revision of Order Prejudicial to Revenue 23 5.20

108 Revision of other Orders 24 5.22

109 Recovery of Tax Dues : 30 to 40 5.24

a. Recovery of tax dues by AO 30 5.24
b. Recovery of tax dues by TRO 31 5.24

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c. Modes of recovery of tax dues 32 5.24

d. TRO by whom recovery of tax dues is to be 33 5.24
effected
e. Recovery of tax dues in case of a company 34 5.24
in liquidation
f. Liability of Manager of a Company 35 5.24
g. Joint and several liability of participants 36 5.24
h. Recovery through State Government 37 5.25
i. Recovery of tax dues in pursuance of 38 5.25
agreements with foreign countries or
specified territory
j. Recovery by suit or under other law not 39 5.25
affected
k. Interest for default in furnishing return 40 5.25
and payment or deferment of advance tax

110 Penalties : 41 to 47 5.26
a. Penalty i.r.t undisclosed Foreign Income & 41 5.26
Asset
b. Penalty for failure to furnish return i.r.t 42 5.26
foreign income & Asset
c. Penalty for failure to furnish ROI or for 43 5.26
furnishing inaccurate particulars about an
asset outside India
d. Non applicability of penalty u/s 42 & 43 Proviso to sec 42 5.26
& 43
e. Penalty for default in payment of tax in 44 5.26
arrear
f. Penalty for other defaults 45 5.27
g. Procedure 46 5.27
h. Bar on limitation for imposing penalty 47 5.28

111 Offences & Prosecution 48 to 58 5.29 to 5.34

112 Agreement with Foreign Countries 73 5.34

113 Authentication of notices and other documents 75 5.35

114 Notice Deemed to be Valid in certain cases 76 5.36

115 Appearance by approved Valuer in certain 77 & 78 5.36

matters or authorized representative
116 Rounding off of Income, Value of asset and tax 79 5.36

117 Assessment not to be valid on certain grounds 81 5.37

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118 Bar of suits in Civil Courts 82 5.37

119 Income Tax papers to be available for the 83 5.37

purposes of this Act
120 Certain provisions of Income Tax Act shall apply 84 5.37

121 Power to make rules 85 5.38

122 Power to Remove difficulties 86 5.38

123 Amendment of PMLA 88 5.38

CHAPTER 6 : TAXATION OF E- COMMERCE

TRANSACTIONS

124 What is E-Commerce ? - 6.2

125 Issues & Problems in Taxing E-Commerce - 6.3 to 6.6

Transactions.
126 How is Business Transacted through E-Commerce - 6.6
?
127 Permanent Establishment in E-Commerce ? - 6.8

128 Equalization Levy Sec 6.10

165/166/170/171
etc. of Finance
Act 2016

CHAPTER 7 : TAX TREATIES: OVERVIEW,

FEATURES, APPLICATION &
INTERPRETATION

129 International Court of Justice Article 38(1) 7.2

130 Sources of International Tax Law - 7.2

131 Double Taxation & Connecting Factors: - 7.3

a. Jurisdictional Double Taxation
b. Economic Double Taxation
132 Tax Treaty : An Overview:
(1) Definition of Treaty 7.4
(2) Role of Tax Treaties 7.5
(3) Types of DTAA ( Limited &Comprehensive) 7.5

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(4) Directive Principles set out in Constitution Article 51 7.5

(5) Need for Tax Treaties 7.6
(6) Tax Information Exchange Agreements 7.7 to 7.13

133 Features of Tax Treaties: - 7.13 to 7.20
(i) Tax Residency
(ii) Allocation of Taxing Rights
(iii) Non Aggravation principle
(iv) Tax Credit mechanism
(v) Exchange of Information
(vi) Limitation of Benefits

134 APPLICATION OF TAX TREATIES: -
(1) Article 4- Gateway to avail Tax Benefits 7.20
(2) Computation of Income Liable for Tax 7.21
(3) Distributive Rule 7.21

135 Interpretation of Tax Treaties: -
(1) Introduction 7.22
(2) Basic Principle of Interpretation of a 7.22 to 7.24
Treaty ( Before VCLT )
(3) Extrinsic Aid to Interpretation of a Treaty 7.24 to 7.26
(4) Commentaries on OECD/UN Model 7.26
(5) Foreign Courts Decision 7.27
(6) Ambulatory vs Static Approach 7.27
(7) Ambulatory Approach subject to 7.28
Contextual Interpretation
(8) Objective of Tax Treaties as per 7.28
OECD/UN/INDIA

136 Process of Negotiating a Tax Treaty 7.30

137 Role of Vienna Convention in Application & - 7.30

Interpretation of Tax Treaties

CHAPTER 8 : ANTI AVOIDANCE

MEASURES:

138 Controlled Foreign Corporations & Effect in Indian - 8.2 to 8.9
Context
139 BASE EROSION & PROFIT SHIFTING: 8.9

140 Impact of Globalisation 8.9

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141 Growth of E-Commerce and consequent 8.10

aggressive Tax Planning
142 Adverse Effects of BEPS 8.10

143 Overview of BEPS 8.11

144 Addressing the challenges of the Digital ACTION PLAN 1 8.15

Economy.
Equalization Levy &
Significant Economic Presence ( FA 2018 )
145 Neutralize the Effects of Hybrid Mismatch ACTION PLAN 2 8.18
Arrangements
146 Strengthen Controlled Foreign Company Rules ACTION PLAN 3 8.22
(CFC)
147 Interest Deductions and other Financial ACTION PLAN 4 8.24
Payments.
Sec 94B.
148 Counter Harmful Tax Practices. ACTION PLAN 5 8.27
Sec 115BBF.
149 Preventing Treaty Abuse ACTION PLAN 6 8.29

150 Prevent the Artificial Avoidance of Permanent ACTION PLAN 7 8.32

Establishment Status:
Amendment in UN/OECD MC & FA 2018
151 Transfer pricing outcomes in line with value ACTION PLAN 8 8.34
creation/ Intangibles /Risk and capital and other TO 10
High Risk Transactions
Safe Harbour Rules 2017.
152 Measuring & Monitoring BEPS ACTION PLAN 11 8.37

153 Disclosure of Aggressive Tax Planning ACTION PLAN 12 8.39

Arrangements :
Note: CRS Avoidance Arrangements & Opaque 8.41
Offshore Structures
154 Re-examine Transfer Pricing Documentation. ACTION PLAN 13 8.42
Sec 286.
155 Making Dispute Resolution More Effective ACTION PLAN 14 8.48

156 Developing a Multilateral Instrument ACTION PLAN 15 8.49

157 BEPS effect in Indian Tax Regime 8.52

158 GAAR Section 95 to 102 8.53 to 8.71

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CHAPTER 9 : OVERVIEW OF MODEL TAX

CONVENTION

159 Introduction, Difference between OECD & UN 9.2
Model Convention
160 Title & Preamble to Model Conventions 9.6

161 Persons Covered: Article 1 9.7

a. Fiscally Transparent Entity discussion
162 Taxes Covered Article 2 9.8

163 General Definitions Article 3 9.10

164 Resident: Article 4 9.12

a. Tie breaker Rule
b. Case by Case Approach
165 Permanent Establishment : Article 5
a. Definition of PE 9.17
b. Inclusive list of PE 9.18
c. Construction PE/ Service PE (Only UN) 9.18
d. Exclusion of PE 9.19
e. Anti-Fragmentation Rule Para 4.1 9.22
f. Agency PE (2017 Updation) 9.23
g. Insurance PE (Only UN Model) 9.24
h. Dependent Agents are PE 9.24 & 25
i. Closely Related Enterprise 9.26

166 Business Profits: Article 7 9.27 to 9.33
a. Force of Attraction principle ( Only UN )

167 Interest Article 11 9.33

168 Royalties Article 12 9.37

169 Fees for Technical Services ( 2017 Updation ) Article 12A 9.40

170 Capital Gain Article 13 9.43

171 Independent Personal Services ( Only UNMC) Article 14 9.47

172 Other Income Article 21 9.48

173 Exemptions from Double Taxation: Article 23 9.50

Exemption Method 23A 9.50
Credit Method 23B 9.53

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174 Non Discrimination Article 24 9.55 to 9.58

175 Mutual Agreement Procedure Article 25 9.58 to 9.63

176 Exchange of Information Article 26 9.63 to END.

ALL THE BEST TO THE STUDENTS

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