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Event Description:

Programme Objectives The Advanced Seminar on Tax Treaty Application will provide participants who have a reasonable understanding of the application of tax treaties with an opportunity to examine in detail relatively complex tax treaty application, interpretation and policy issues. This will include current treaty issues relating to the taxation of business profits, the permanent establishment definition, royalties, the taxation of foreign employees, treaty interpretation and countering treaty abuse, including the meaning of beneficial ownership and the application of the principal purposes general anti avoidance test (PPT). The seminar will also discuss the BEPS multilateral instrument that India has signed and ratified to rapidly adopt the BEPS tax treaty measures in India’s tax treaties. The seminar will be especially useful for officials who are, or will be, involved with the application and interpretation of tax treaties, consideration of competent authority issues and the negotiation of tax treaties. The seminar will focus on the consideration of practical application issues through the discussion of case studies and selected Indian court cases.

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