TaxTonic #36: Taxed Abroad? – Know Your Credits!
- Year of Publication: 2023
- ISBN: 0
Episode Duration:
100 Minutes
Episode Background:
'TaxTonic', a 'subscriber only' thought leadership series, is Taxsutra's endeavour to consistently deliver top notch technical content to it's readers. The labyrinth of tax rulings on convoluted transactions keeps the world of taxation unpredictable and ever-evolving. This series will feature engrossing presentations, incisive analyses and a deep-dive by the tax experts on burning issues & controversies. So, gear up for a 'tonic' to chisel your tax mind and challenge your wit.
Speaker:
- Mr. Vishal Gada (Aurtus Consulting LLP)
Moderator:
Mr. Sachin Sastakar (Chartered Accountant)
What shall the episode cover?
Double taxation of income can occur either economically or juridically. To remove the impact of the juridical double taxation, one of the methods adopted in the Double Taxation Avoidance Agreement (DTAA) and Income Tax Act, 1961 (ITA) is to provide a tax credit for the taxes paid in the source jurisdiction. The Foreign Tax Credit (FTC) can either be full or progressive. Section 90 and Section 91 of ITA deals with the law and practice relating to FTC. As a rule, FTC is allowed to the person in the resident jurisdiction who has paid the tax in the foreign jurisdiction. Few interesting situations or exceptions such as tax paid as buy back tax on shares or dividend distribution tax on dividend income as well as situation relating to taxes paid by fiscally transparent entities makes FTC complex. Nuances of Section 90 and 91 read with the recently incorporated Rule 128 attempts to either answer or create challenges.
In the this episode of TaxTonic, Taxsutra brings to you an incisive discussion to understand the law and practice relating to FTC as per the provisions of ITA and DTAA. The webinar broadly covers:
1. Various types of Foreign Tax Credits.
2. BEPS 1.0 impact on FTC credit mechanism.
3. Domestic tax regulations and their nuances.
4. FTC under Section 90 v. Section 91.
5. Practical challenges for FTC.
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
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- Year of Publication: 2023
- ISBN: 0
Episode Duration:
100 Minutes
Episode Background:
'TaxTonic', a 'subscriber only' thought leadership series, is Taxsutra's endeavour to consistently deliver top notch technical content to it's readers. The labyrinth of tax rulings on convoluted transactions keeps the world of taxation unpredictable and ever-evolving. This series will feature engrossing presentations, incisive analyses and a deep-dive by the tax experts on burning issues & controversies. So, gear up for a 'tonic' to chisel your tax mind and challenge your wit.
Speaker:
- Mr. Vishal Gada (Aurtus Consulting LLP)
Moderator:
Mr. Sachin Sastakar (Chartered Accountant)
What shall the episode cover?
Double taxation of income can occur either economically or juridically. To remove the impact of the juridical double taxation, one of the methods adopted in the Double Taxation Avoidance Agreement (DTAA) and Income Tax Act, 1961 (ITA) is to provide a tax credit for the taxes paid in the source jurisdiction. The Foreign Tax Credit (FTC) can either be full or progressive. Section 90 and Section 91 of ITA deals with the law and practice relating to FTC. As a rule, FTC is allowed to the person in the resident jurisdiction who has paid the tax in the foreign jurisdiction. Few interesting situations or exceptions such as tax paid as buy back tax on shares or dividend distribution tax on dividend income as well as situation relating to taxes paid by fiscally transparent entities makes FTC complex. Nuances of Section 90 and 91 read with the recently incorporated Rule 128 attempts to either answer or create challenges.
In the this episode of TaxTonic, Taxsutra brings to you an incisive discussion to understand the law and practice relating to FTC as per the provisions of ITA and DTAA. The webinar broadly covers:
1. Various types of Foreign Tax Credits.
2. BEPS 1.0 impact on FTC credit mechanism.
3. Domestic tax regulations and their nuances.
4. FTC under Section 90 v. Section 91.
5. Practical challenges for FTC.
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
