International Taxation in CA Final New Syllabus – Expected Changes

Changes in CA Final Syllabus – International Taxation in CA Final New Syllabus. CA Final New Syllabus / Course is undergoing a change and the new syllabus can be implemented at any point of time. In this article we discuss syllabus of CA Final International Taxes, Here below we provide all expected changes in International Taxation. Now check complete details for International Taxation in CA Final New Syllabus from below….

International Taxation in CA Final New Syllabus

Change in CA Final Syllabus – International Tax as a subject

• Let’s talk about expected change in syllabus of CA Final. As all of you know that CA syllabus / course is undergoing a change and the new syllabus / change can be implemented at any point of time.
• Amongst other changes, a major/ big change which is happening is introduction of ‘International Tax’ as a separate subject for 100 marks – Yes, you heard it right – International Tax as a subject of 100 marks in CA Final New Syllabus.

Please Note – Currently we provide only expected changes in CA Final New Syllabus, No official news or announcement is available for above changes at ICAI site, if ICAI issued any official news about any changes in CA Final New Syllabus related to International Taxation, then we update this page immediately so currently read this information as reference purpose only…

• Please note that as of now, based on unpublished information, it seems that ISCA would be replaced with another subject. In this regard, 6 optional subjects have been introduced and International Tax is one choice out of such 6 subjects.
• In simple words, existing paper no. 6 of CA Final i.e. ISCA would be no more and students can choose another subject of their own choice out of such 6 optional subjects.
• The list of 6 options available to students is expected to be as follows:
  • Risk Management
  • International Taxation
  • Economic Laws
  • Financial Services & Capital Markets
  • Global Financial Reporting Standards
  • Multidisciplinary case study
• It also needs to be clarified that whether International Tax would form part of Direct Taxes (existing paper number 7) as well or not. It is difficult to comment with certainty on this aspect but the unofficial circulations show that International Tax would also be introduced as separate subject for 30 marks with Direct Taxes.

So, as of now, following are the possibilities with respect of International Taxation as a subject in CA Final New Syllabus:

Objective of Introduction of International Taxation as a separate subject in CA Final New Syllabus

• It is expected that in order to provide expert knowledge on International Taxation to the students who would be future professionals, this has been introduced as a separate subject.
• Though international taxation is a part of current syllabus of CA Final Direct Taxes, but due to its less weightage in examination, such an important topic is generally ignored or even if not ignored, it is not enough for imparting an expert knowledge to the CA Final students.
• Now a days, a significant number of businesses are going beyond local boundaries and have global presence. This involves cross-border taxation/ international taxation issues, transfer pricing, etc. Therefore, it is required that a professional is equipped with expert knowledge on this subject.  In order to ensure that CA student has such knowledge since the beginning of his / her career, the introduction of International Taxation as a separate subject in CA Final New Syllabus can be said to be an extremely positive step.

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When would this new scheme of syllabus would be applicable

• Firstly, it is to be noted that there is no official announcement on the timeline for applicability of new CA Final Syllabus.
• However, if thoughts are reasonably constructed, in that case, one can think of applicability of this new CA Final Syllabus from the time new GST Law will replace existing Paper 8 (Indirect Tax Laws) i.e. May 2018 and onwards.
• The above is subject of official announcement of ICAI.[/box]

  If you are searching CA Final Best Faculty list for “International Taxation” then CAknowledge.in Team Recommended Anuraag Singhaal CA(2005) and CPA(USA)(2008).

  Contents of International Tax Subject

  • This subject is very wide and includes various international commentaries as well.
  • As a layman, it can be said that International Tax includes Double Taxation Avoidance Agreement & Transfer Pricing including the International Tax concepts which are there in Income-tax Act, 1961. And the same is expected to be in the course as well.
  • Following may be expected content of International Taxation Subject in new CA Final Syllabus:
  • Economic analysis of international taxation à History and background of double taxation, what is treaty, impact of double taxation avoidance agreement in India, etc.
  • Broad features of Income-tax Act, 1961
  • Taxation of non-residents à Foreign income, categories of income (royalty or fees for technical services or business income), dividend and interest, withholding tax, etc., treaty shopping, treaty overrides the Act, etc.
  • Double taxation à Its concept, capital export neutrality, capital import neutrality, method of avoiding double taxation, etc.
  • Double Taxation Avoidance Agreements à Interpretation of tax treaties, scope of tax treaties, definition, taxes covered, residence under tax treaties, business profits, permanent establishments (attribution rule vs force of attraction rule), associated enterprises, royalties, fees for technical services, capital gains, independent personnel services, dependent personnel services, other income, elimination of double taxation, limitation of benefits, non-discrimination clause, etc.
  • Transfer Pricing à International Transactions, Associated Enterprises, Arm’s Length Price, Advance Pricing Arrangement, Safe harbour, Range Concept, Multiple Year Data, Important judgments, etc.
  • Advance Rulings à Introduction, Procedure in detail for making an application, purpose of seeking advance ruling, etc.
  • Contentious issues à e-commerce transactions, taxation issues in e-commerce transactions, summary of findings contained in OECD report, etc.
  • Reference Material à OECD Model Double Taxation Convention, Double Taxation Avoidance Agreements, – Circulars/ Instructions, important judgement, etc.
  • The precise content of syllabus would be available post official release of ICAI.
  • The important point to note on this subject is that it is not only wide but it may be very complicated too if someone does not have real / practical & significant background on it including international exposure and knowledge about international commentaries.
  • Therefore, students have to be considerate while planning studies for international taxation.

  High Scoring Subject

  • First of all, let me tell you that these 100 marks could change the complete dynamics of your DT subject / 2nd Group in CA Final because – it may be going to be a HIGH SCORING SUBJECT à significantly opposite situation in comparison to ISCA where, as a general feedback, the ratio of outstanding performance of students was less.
  • However, it can be high scoring provided that you understand this subject from a high experienced faculty in International Tax.

  Special features of International Tax

  • Let me tell you that International tax is going to be different from Direct Tax Laws in terms of teaching because Direct Tax Laws work on domestic principles. On the other hand, International Tax is framed based on International Principles which have broadly more or less same fundamentals across the world and globe.
  • Every country generally follows same fundamental laws with few / some modifications to adapt the International Tax Law.
  • Therefore, since as a faculty I have significant experience in International Tax & Transfer Pricing on practical assignments, I have absolutely great command on the concepts of International Tax and ability & technique to transform the knowledge to you.
  • And the objective of scoring high marks and to make career of students may be fulfilled.

  Opportunities in MNC and across the world

  • Students, also understand that ‘International Tax’ is the one which can provide you immense and great opportunity to work in India for MNCs.
  • It also makes you competent to go for GLOBAL opportunities – as I told you that it works on broadly same fundamentals / concepts across the world.

  Focus of Indian Government

  • Also, Indian Government is focused on ‘Make in India’ thereby opening the door for MNCs to work in India –in manufacturing & service sectors, etc. This would result in increased number of job opportunities for you to make a successful career in International Tax.
  • Let me tell you that there are separate wings of International Tax (& Transfer Pricing) in Income Tax Department.
  • Without me explaining you in much detail, you can understand focus of government on this subject.

  Conclusion

  • In order to transform knowledge on this subject, your International Tax mentor – Anuraag Singhaal CA (2005) & CPA (2008) would be launching classes for this subject – to help you in achieving your goals to become a successful professional and a leader.
  • For registration and enquires in Delhi contact – 9711616631 / 9711574403
  • Address – Pitampura, Delhi – 110034
  • REGISTERATION IN OTHER METROS STARTING SOON
  • FACEBOOK PAGE – @FINAL DIRECT TAX CLASSES

  Introduction of Author

  • As an introduction, would like to inform you that I am writing this article to give you an update on International Tax and Transfer Pricing.
  • My name is Anuraag Singhaal – Your International Tax & Transfer Pricing Expert
  • I am a CA(2005) & CPA(USA)(2008) with 11 years of experience.
  • I have worked with PwC, Deloitte & Reliance Industries Group, etc. Now, am running my own tax consulting firm and also engaged in mentoring CA Final Students for DT Subject.  I also teach to CPA students.
  • During my career, I have extensively worked on wide variety of assignments on International Tax, Transfer Pricing & Corporate Tax. I have worked for MNCs, Foreign Companies, Permanent Establishments (PEs), Indian Listed Companies, US Listed Companies, Big Indian Corporates, etc.
  • These companies were engaged in different sectors ranging from manufacturing to services to entertainment sector to financial services sector and so on.
  • Some of corporates for which I have worked are top 100 companies of the world.
  • Due to this, I have gained significant and all round experience on International Tax & Transfer Pricing and Corporate Tax.

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