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2014
2 DAYS’ WORKSHOP
Royalty And FTS Payments - Law And Practical Aspects
After conducting two successful workshops at Mumbai and Delhi and another one scheduled for Bangalore, Taxsutra is happy to bring the 2 day workshop on Royalty and FTS payments
2 DayS’ Workshop On Royalty And Fts Payments – Law And Practical Aspects
Dates : March, 14 & 15 2014
(Friday& Saturday)
at Pune
Courtyard by Marriott ,
law and practical aspects to Pune!
Venue :
Next to Jehangir Hospital,
Bund Garden Road,
Pune – 411001
The workshop intends to cover all the aspects of domestic & treaty law and practical aspects. The workshop will be conducted by experienced professionals with rich experience of consulting and
2 Days’ Workshop
industry.
Every taxpayer needs to obtain a certificate from CA confirming WHT implications. IT Department too has increased its focus and is closely monitoring foreign remittances, with online submission of CA certificates coupled with increased interaction with the Bankers. These changes require Indian Businesses (local as well MNCs) to have a greater focus on compliance. Manag-ing the internal process & ensuring proactive involvement of tax team in business/contracts is also becoming critical.
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In recent years, scope of taxation of royalties and FTS under Indian Income Tax Act has been considerably enlarged (eg. various amendments to Sec 9). There has been considerable Indian juris-prudence on treaty interpretation principles. The increase in tax rate on royal-ty/FTS to 25% (if treaty relief is not available), will also create considerable tax impact.
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Several corporates in India (MNCs as well as Indian Groups) make large payments to foreign entities. Determining TDS (also known as withholding tax or WHT) implications on these payments is critical, before making remittance outside India. A large majority of these payments are towards services or use of assets/intellectual property. These could be taxable in India, as royalty or Fees for Technical Services (FTS). The tax implications on royalty/FTS payments are relevant since in many such contracts, taxes are borne by Indian payer.
2 Days’ Workshop
FOCUS AREAS TARGET AUDIENCE
Finance Professionals
Tax Consultants
Tax & Regulatory Service Professionals
Legal Professionals/Taxation Lawyers
Tax Counsel or Tax Attorney
Workshop Speakers:
11.45 am to 1 pm Session 2 (75 minutes * 2 sessions)
Taxability under DTAA
“Make available” concept
Unique FTS clauses under tax treaties
Relevant rulings on each of the issues
MFN clause
DAY 1
am to 11.15 am Session 1 (75 minutes)
General source principles & deeming fiction
Definition under Sec 9(1)(vii) – technical,
managerial & consultancy
Exclusions from Definition under Sec 9(1)(vii)
& transactions between non-residents
Territorial nexus – IHI ruling status
2 pm to 3.15 pm Session 3 (75 minutes)
ax treatment where PE exists T
IPS vs FTS under tax treaty
Special issues relating to Oil & Gas sector
Rates in force and conditions u/s 115A
Definition under Sec 9(1)(vi)
Exclusions from Definition under Sec 9(1)(vi)
& transactions between non-residents
Definition under tax treaty
Tax treatment where PE exists
Domestic tax definitions & exclusions of royalty & FTS taxation
Treaty concepts under Article 12 and other relevant articles
Taxation of special transactions like software, lease line, equipment
Important concepts like TRC, Beneficial Ownership, MFN clauses
Key compliance in foreign remittances, PAN & computation issues
Case studies and in-depth analysis of rulings
Managing foreign payments - internal process, contractual aspects and risks
Taxation of “Fees for Technical Services” under IT Act Taxation of “Fees for Technical Services” under Tax Treaty
FTS - Specific taxability issues Taxation of “Royalties” under IT Act and Treaty
Bijal Ajinkya, Partner, Khaitan & Co.
M. P. Lohia, Executive Director, Ernst & Young LLP
Mrugen Trivedi, Technical Director, KPMG in India
Nihar Jambusaria, Taxation, Reliance Industries Limited
Nitin Deshmukh, Head of Tax, Eaton Corporation
Pramod Joshi, Partner, Deloitte India
Sudhir Nayak, Partner, Sudit K Parekh & Co.
ax practice Leaders
Tax Managers & T
3.45 pm to 5 pm Session 4 (75 minutes)
Reimbursement taxability ( i ncluding credit card transactions)
10
2 Days’ Workshop
per delegate.
Contact for an Invoice and for further details you can also sales@taxsutra.com call Samita Shetty
on 09833145124.
Contact us now to confirm your registration.
Cheque/DD should be payable to* "Realtime Taxsutra Services Pvt. Ltd"*
DAY 210 am to 11.15 am Session 5 (75 minutes) 11.45 am to 1 pm
Lease line charges / IPLC
Equipment leasing
Satellite payments
E-
TDS Gross-up
TRC formalities
Beneficial ownership
CA certificate (format, process and documentation)
PAN and Sec 206AA applicability
Bankers’ expectations& FEMA filings
2 pm to 3.15 pm Session 7 (75 minutes) 3.45 pm to 5 pm Session 8
Contract drafting
Maintaining documentation,
Processes between Finance , Tax and Other Business
Functions on foreign tax payments
Managing Service tax, customs and Transfer Pricing on
royalty and FTS payments,
Compliance requirements for foreign Group companies
earning income in India,
Obtaining lower TDS / NIL TDS certificate
Taxation of “Royalties”– Special transactions Royalty/FTS payments – key compliances
Case Studies – 3/4 case studies followed by discussion. Panel discussion on :Managing foreign payments – internal processes, how to manage risks
Session 6 (75 minutes)
commerce transactions & BEPS issues
TDS requirements u/s 195Software
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