Certificate Course in International Taxation and Transfer Pricing

Three months fully online Certificate programme by NUJS, Kolkata Scroll Down to Learn More

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About the Course

Total Fees: INR 8,000 5,000

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-months 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 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 skillsets?

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

Create strategies on structuring of cross-border transactions to reduce your overall tax bill. Expand your practice area in Advise businesses on how related party entities should carry business in accordance with the transfer pricing rules. Negotiating and drafting of 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

Who are the typical audience for the course?

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

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 international payments such as Google Adwords, Amazon Web Services, etc.?
  • Sources of International Tax Law
    • Domestic law provisions
    • Double Taxation Avoidance Agreements and 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
    • Taxation of Business Process Outsourcing in India
    • Taxation of cross-border e-commerce transactions
  • Business Connection under Income Tax Act
  • 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

    • What is an associated enterprises
    • Meaning of Associated Enterprises under Income Tax Act, 1961
    • Difference between “Close Connection” and “Associated Enterprise”
    • Related Party Transaction v. Associated Enterprises
    Identifying an Associated Enterprise- Concept of “Control” and “Management” Transfer Pricing Rules

Case study 1 - How Google, Apple, Amazon and other global corporations save billions in taxes due to smart tax structure

  • Temporary v. Permanent tax savings
  • Tax planning and double tax treaty
  • International tax structuring for global businesses
  • For Manufacturing Business
  • For Technology and Intellectual Property Driven businesses
  • For Financial Sector\
  • For High Net-Worth Individuals
  • Use of tax havens Tax Haven

  What are tax haven

  • Popular tax havens for India
  • Case study of Mauritius and alternatives to Mauritius
  • Penalties under Indian domestic law
  • Regulation of tax havens
  • Tax avoidance, tax evasion and  black money
    • General and Special Anti-Avoidance Rule
    • Black Money law and its relation with international tax
    • FATCA
  • Information exchange provisions
    • International cooperation under DTAAs
    • Tax Information Exchange Agreements
  • 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

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.

Puneet Bhasin

Founder, Cyberjure Legal Consulting, Mumbai

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