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PAPER 4: DIRECT TAX LAWS INTERNATIONAL TAXATION CA Final Group 2

Syllabus

Objective

a. To acquire the ability to analyse and interpret the provisions of direct tax laws and recommend optimal solutions to practical problems in a tax efficient manner; and
b. To apply the provisions of direct tax laws and the concepts, principles and provisions of international taxation to recommend solutions to issues involved in cross border transactions.

Contents

1 (i) Comprehensive computation of income-tax liability of companies and other entities under the alternative tax regimes under the Income-tax Act, 1961 to optimise tax liability
- General provisions under the Act for computation of total income and tax liability of companies and other entities
- Special tax regimes under the Act for companies and other entities
- Optimisation of tax liability of companies and other entities through tax planning
(ii) Special Provisions relating to charitable and religious trust and institutions, political parties and electoral trusts, business trusts, securitization trusts, investment funds and other funds/trusts
(iii) Anti-avoidance provisions under the Act
(iv) Provisions to address tax challenges on digitalisation

2. Tax Administration and Appellate Mechanism

(i) Deduction, Collection and Recovery of Tax i Income-tax Authorities
(ii) Assessment Procedures
(iii) Appeals and Revision, and Dispute Resolution
(v) Provisions to counteract unethical tax practices
- Taxation of undisclosed income under the Income-tax Act, 1961
- Taxation of undisclosed foreign income and assets
- Penalties and offences and prosecution
(vi) Miscellaneous Provisions
(vii) Tax Audit

3. International Taxation

(i) Taxation of cross border transactions and Non-resident taxation under the Income-tax Act, 1961, including
- Transfer Pricing
- Non-resident Taxation
- Double Taxation Relief
- Advance Ruling
(ii) Other Aspects of international Taxation, namely,
- Significant articles of OECD and UN Model Tax Conventions
- Fundamentals of BEPS
- Application and interpretation of Tax Treaties
- Latest developments in International Taxation

 

Note: If any new legislation(s) are enacted in place of an existing legislation(s), the syllabus will accordingly include the corresponding provisions of such new legislation(s) in the place of the existing legislation (s) with effect from the date to be notified by the Institute. Similarly, if any existing legislation (s) on direct tax Laws
ceases to be in force, the syllabus will accordingly exclude such legislation(s) with effect from the date to be notified by the Institute.

Further, the specific inclusions/exclusions in any topic covered in the syllabus will be effected by way of Study Guidelines every year, if required. Specific inclusions/exclusions in a topic may also arise due to additions/deletions made every year by the Annual Finance Act.