Double Taxation Treaties (Concepts, Practices & Trends) by K R Sekar (Set of 2 Vols.) – 1st Edition 2024

Book Coverage:

Chapter 1 – Introduction to Double Taxation Convention- Basics and Concepts
Chapter 2 – Principles of Interpretation of Treaties
Chapter 3 – Interpretation of Double Taxation Avoidance Agreement- Principles
Chapter 4 – Interpretation of Article 3(2)
Chapter 5 – Definition of Residence and Test of Residency
Chapter 6 – Application of Tie Breaker clause
Chapter 7 – Place of Effective Management
Chapter 8 – Introduction to Permanent Establishment
Chapter 9 – Fixed Place PE
Chapter 10 – Installation, Construction PE
Chapter 11 – Preparatory or Auxiliary Services
Chapter 12 – Equipment- Permanent Establishment
Chapter 13 – Permanent Establishment under in E commerce transactions
Chapter 14 – Agency Permanent Establishment- Concepts and Issues
Chapter 15 – Service PE and Issues
Chapter 16 – Attribution of Profits- Introduction
Chapter 17 – Associated Enterprises under Article 9
Chapter 18 – Beneficial Owner under Treaty Laws
Chapter 19 – Dividends and Interest
Chapter 20 – Royalty and Fees for Technical Services
Chapter 21 – Most Favoured Nation Clause-Concept, Application and Issues
Chapter 22 – Recent Supreme Court Ruling on Most Favoured Nation Clause-Impact Analysis
Chapter 23 – Income from Employment, Professional Services and Sportsperson
Chapter 24 – Independent Personal Services
Chapter 25 – Taxation of Artistes and Sportsperson
Chapter 26 – Capital Gains and Indirect Transfer
Chapter 27 – Foreign Tax Credit
Chapter 28 – Limitations of Benefit and Anti-Avoidance Provisions
Chapter 29 – Multilateral Agreements or Instruments (MLIs)
Chapter 30 – Digital Economy & Taxation
Chapter 31 – Select Judicial Precedents related to E Commerce
Chapter 32 – Cryptocurrency and Taxation
Chapter 33 – Emerging Issues on Taxation of New Age Industries
Chapter 34 – OECD Pillar 1 and Pillar 2- Concepts, Analysis and Issues
Chapter 35 – International Tax Body- Recent Developments & Role of India