Certificate Course in International Taxation and Transfer Pricing



Three months' Certificate programme by NUJS Kolkata Scroll Down to Learn More

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About the Course

Total Fees: INR 8,000 5,000

Get immediate access on Web, Android and iOS on enrolment

Duration: 3 months

Can you advise someone in structuring the global operations of a business to save tax?

Do you know how to optimize tax liability for cross-border transactions?

Do you know how to use tax havens for high-value business transactions?

How can you save multinational companies from overlapping tax regimes of multiple jurisdictions?

How should you deal with tax authorities in case of international tax disputes?

What planning measures can you adopt in case of complex international transactions to minimize tax uncertainty?

Global corporations such as Apple, Google, Amazon and Facebook save billions in taxes due to effective tax structuring and tax planning. To mitigate tax liability, Google uses a complicated legal structure that has saved it $47.4 billion. Multinationals that have subsidiaries in various countries, including markets where they benefit from lax tax laws let them save an estimated $90 billion in federal income taxes each year. Further, 60% transactions across the world are between related party entities and involves transfer pricing.

In this context, there is an ever-expanding opportunity for professionals to acquire highly-specialised skills in international taxation advisory and litigation. Further, this course will also provide you with an understanding of complex issues involved in this spectrum and as to how can you advise companies to mitigate tax liabilities?

At law school, you only learn about basic concepts of transfer pricing and international transactions and how transfer pricing is calculated but this course will enable you to use these concepts for structuring transactions and advise multinational corporations as to how can they save tax.

NUJS, Kolkata has launched a three-month certificate course in International Taxation and Transfer Pricing for young law students, CA, CS, lawyers, management consultants, businessmen, entrepreneurs, etc.

What will you learn in this course?

  • How to apply advance tax planning strategies to a unique cross-border structured financial product.
  • How tax haven countries can help you mitigate your tax liability
  • How to interpret tax-treaties.
  • How you can resolve disputes effectively in the field of international taxation.
  • How to identify and resolve tax controversy issues at the time of structuring a transaction.
  • How you can claim benefits under DTAA.

How can you use this skillset?

Understanding of international taxation and transfer pricing can be useful in the following ways in one's professional/academic career:

Create strategies on the structuring of cross-border transactions to reduce your overall tax bill. Expand your practice in International Taxation domain. Advise businesses on how related-party entities should carry business in accordance with the transfer pricing rules. Learn how to negotiate and draft advance pricing agreements.

 

Other features of the course

  • Learn anytime and from any location - 24 x 7 access available on mobile and tablet devices (Android) and on web.
  • Faculty includes experts from the most reputed corporate law firms. Get doubts cleared in 24 hours.
  • Learning materials comprise of video discussions with experts, animation, study materials, checklists. Access sample agreements and approval applications.
  • Get doubts cleared within 24 hours over a discussion forum.
  • Those who complete the course successfully will receive certification from NUJS, Kolkata - certification will be based on performance in an online test.

 

Target audience

This course is specifically designed for young law students, CA, CS, lawyers, management consultants, businessmen, entrepreneurs, etc.

 

The certificate awarded by NUJS will have the course name as "Certification in Transfer Pricing Laws".

Course Contents

Why should non-tax experts know about transfer pricing?

When are principles of international taxation attracted?

When does transfer pricing become applicable?

Does international tax law apply to you if you don't have an office offshore?

Sources of International Tax Law

Domestic law provisions  

Double Taxation Avoidance Agreements and Structure

  • Permanent Establishment (in Model Agreements and DTAAs)
  • Capital Gains
  • Royalty
  • Fee for Technical Services
  • Tax Information Exchange Provisions
  • Tax Credit / Refund Provisions   

Model Tax Treaties and treaty interpretation of DTAAs under VCLT and OECD

Business Connection under Income Tax Act

International Tax Issues in Secondment Arrangements

Arms Length Pricing and methods

  • Comparable uncontrolled price method (CUP)
  • Resale Price Method
  • Cost-Plus Method
  • Transactional net Margin method(TNMM)
  • Profit Split Method

How to choose an appropriate method     

Role of an advanced pricing agreement  

Associated Enterprises

Permanent Establishment

Taxation of Foreign Companies_ PoEM Rules

Safe Harbour Rules

Place of Effective Management

Sample Transfer Pricing Agreement

International tax structuring for global businesses

Case study of India - Mauritius DTAA

How Foreign Tax Credit Works

International Tax Structuring and Tax Havens

Tax Structuring, Base Erosion and Profit Shifting (BEPS)

Why the amended Mauritius India DTAA will not impact foreign investment

General Anti-Avoidance Rule (GAAR)

Do Commissionaire arrangements constitute a PE ?

Penalties under Indian domestic law (covered)

Tax avoidance and tax evasion

  • General Anti-Avoidance Rule (GAAR) and Special Anti-Avoidance Rule
  • FATCA

Information exchange provisions

  • International cooperation under DTAAs
  • Tax Information Exchange Agreements (TIEAAs)
  • Case study of Switzerland’s secrecy norms under DTAAs

How to safeguard against future regulatory risks - Authority for Advanced Rulings (AAR)

Settlement of disputes with tax authorities

Transfer pricing disputes in offshore jurisdictions

Industry Academia Panel

Abhyudaya Agarwal

COO and Co-founder, iPleaders

Jimit Shah

Proprietor at JPS Legal

Ketan Mukhija

General Counsel, SREI Group

Ramanuj Mukherjee

CEO and Co-founder, iPleaders

Sameer Jain

Partner at Pamasis Law Chambers

Shivi Agarwal

Partner, Amicus

Suhas Baliga

Principal, Impact Law Ventures

Sunil Agarwal

Senior Tax Partner, AZB Partners, Noida

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Success Stories

Imagine how it would be if you could navigate the usual legal and regulatory mess with ease, and make better decisions as you scale your business or career growth. Regulatory and legal difficulties is a huge hurdle to doing business in India, and very few people have mastery over it. We are inviting you to find out more about how we can add a touch of magic to your growth. Here are some amazing success stories of our students who have taken up our courses.

My purpose of joining the course is certainly fulfilled; it has given me the much needed practical knowledge of law. All modules in the course are designed with emphases on practical knowledge. The concepts are not explained theoretically but in a practical manner. I personally found the module on business structuring, institutional finance, and raising investment to be most beneficial for me. I am able to utilize this knowledge in my current job also.

Shivam Dubey

Associate, Cyril Amarchand Mangaldas

All that I learned from the course is very relevant to me and helps me every single day. I still refer the course notes. Once, we were working on a transaction which involved export-import compliance. It was something I had never done before and none of my team members had an experience with it. I had only the basic idea about it and that is when I realized that I have studied it in my diploma course. I referred the course material and handled the transaction totally based on the knowledge gained through the diploma course, it gave me the basic idea of what to check and how to check.

Ananya Banerjee

Managing Partner, Unico Legale

I can definitely say that this course has added value to my profile and facilitated my growth. The knowledge gained through this course has boosted my confidence and helped me get through many interviews. I found the modules on Arbitration, FDI, and Corporate Governance to be extremely informative. The module on drafting provided various templates that gave you a framework to build on. The webinars by various industry experts was an added advantage of this course. These were exceptionally outstanding, interactive and provided the much needed insights from a commercial point of view.

Mehak Gupta

Associate, Economic Laws Practice

I am a computer science engineer by education, but an entrepreneur by profession. Having had no formal education in running a business I was always led to a lot of "learning the hard way". When iPleaders launched the course for Entrepreneurship Administration and Business Laws, in an e-learning mode I took up the course with the objective to understand all legal nuances related to running a business. The course covered things like; understanding of ESOP, Sweat Equity, Company Policy, License agreements, IP related law, EULA and lots of other content which made sense for our business.

Atul Gupta

Managing Director of InSync Tech-Fin Solutions Ltd

I am a practicing Cyber lawyer in Mumbai for the past 3 years and have founded Cyberjure Legal Consulting. The course was a very good learning experience, and I am glad I did it. It helped me understand the nuances of many laws which we studied in college, but never went into practical applicability of the same. The stuff I learnt in the course helped me in my matters too, and in structuring e-commerce start-ups.

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Frequently Asked Questions

The course fee can be paid through our online payment gateway, Instamojo. You can pay using your credit card, debit card or net banking by clicking on enroll now.

Enrolment continues throughout the year. If the course fits your aspiration, we recommend you to enrol and start studying immediately.

Once you successfully make the payment and fill the enrolment form. You can access the course by logging to the learning management platform (LMS) http://www.lawsikho.com/login, using your Facebook login credentials (email address not mobile number).

No. These courses are completely online, and you will not need to travel to Kolkata for any requirement of this course.

All the study materials will be provided on the online learning management system and not in hard copy. No hard copy is required or recommended for these courses. For any hard copy provided by iPleaders for some parts of some of the courses which may be available with iPleaders, check with them by calling on the number provided in this website.

There are no discounts available. However course fee for long term courses (1 year or more) can be paid in instalments. To know about instalment options, call 011-331-38901

There are no minimum attendance requirements, as the course shall be taught online through a learning management system which allows you to pursue the course at your own pace and convenience.

The course is conducted through an online learning management system, which enables students to access study materials from anywhere in the world at their own time and convenience. All the study material which includes text, videos, drafting exercises, templates and regular tests will be available only within the LMS and can be accessed using your login id for the LMS. The course can also be accessed through state of the art mobile Apps, which makes learning convenient and accessible on a real time basis.
Live sessions are also conducted online – students who miss the session can watch recorded versions. There will also be some online doubt-clearing sessions between students and faculty.

The minimum eligibility for diploma and certificate courses is XII pass and students from any discipline can enrol in the course. For MA in Business Laws, graduation in any discipline will suffice. Therefore, students of B.Com., BMS, BBA, Science, Arts, Medicine or from any other discipline are eligible to enrol and many have already enroled. The course is targeted at entrepreneurs, managers, consultants and working professionals and will be relevant and useful irrespective of stream and industry. Those would like to start up their own company at some point of time, are interested in a career in management, want to have a grasp on business laws or differentiate themselves by adding a unique skill shall benefit from this course. Please visit our Success Stories page to read about what individuals from different disciplines have to say about the course.

As candidates will be enroling from across India and even abroad, the schedule of every candidate is likely to differ. To accommodate that, the periodic tests will be available on the online portal for a period of time so that you can take them at your convenience. Everyone will be given sufficient opportunity to take the tests.

The online MCQs are executed on the learning management system. You do not need to go to any special centres to take any test or exam. All tests can be taken by logging on to the online learning management system from your home.