Certification Course Article 12 of DTAA - Taxation of Royalties Course by CA Arinjay Kumar Jain
Article 12 of DTAA - Taxation of Royalties Course - Index
Article 12 - Taxation of Royalties​Key Learning Points to be learnt about taxation of Royalties
Which Country has the Right to Tax Royalty Income ? ​
Article 12 (1) – Right of the State of Residence to tax Royalty​
Cases Study on Royalty Arising within a Contracting State - Article 12(1)​
PE Situation – Royalty Attributable To Third State PE
Beneficial Owner – Concept And Issues​
Open Issues and important aspects of Article 12(1)​
Article 12 (2) – Meaning of Royalties ​
What is included within Royalties - Examples ?
Some Issues In Article 12 Payments – Whether Royalties ? ​
Article 12 (3) – Taxation of Royalties when a Permanent Establishment​ exists in Source State
Key Questions to understand Application of Article 12(3)​
Meaning of Effectively Connected ​
Article 12 (4) –Excess Payment due to Special Relationship between Payor and Payee​
Meet Your Instructor
CA Arinjay Kumar Jain
B. Com. , FCA
Director M&A Tax at KPMG Delhi (2006 to 2014) - Worked on International tax with over 750 transaction of Inbound Investment, Outbound Investments, Due diligence, Family Structuring and Succession planning across sectors.
Editor International Tax at Taxmann Publications , New Delhi - Handled the Journal on International Tax with Taxmann Publications, India's oldest Publishing house on tax and corporate law publications.
Faculty at the International tax Course of ICAI during the year 2009 & 2010
Trained over 1500 CA's in International tax till date at Corporates and Consulting Firms.
Created India's first e learning course on International tax for professionals in 2016 with students from over 30 countries.
Erstwhile Faculty for Interns at one of the Big Fours for CA Final aspirants.
Created a repository of over 2000 videos for Students under a Not for profit initiative with over 30,000 subscribers on YouTube.
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