Opportunities for Chartered Accountants in International taxation May 2013 1 - C.A. T. P. Ostwal T.P.Ostwal & Associates The Institute of Chartered Accountants.

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Presentation transcript:

Opportunities for Chartered Accountants in International taxation May C.A. T. P. Ostwal T.P.Ostwal & Associates The Institute of Chartered Accountants of India EASTERN INDIA REGIONAL COUNCIL

2 Opportunities for Chartered Accountants in International Taxation May 2013 T.P.Ostwal & Associates Emerging Areas of Practice  International M& A  Transaction A International M& A Tax Treaty Application & Interpretation Transaction Advisory Re-organisations, Spin offs and Work outs Inbound Structuring Outbound Structuring Transfer Pricing Tax Dispute Resolution including MAP Advance Pricing Arrangements (APA) Turnkey EPC Contracts Taxation of Immigrants & Emigrants

EMERGING TAX PRACTICE AND EXPERTISE 1.Domestic Tax Experts 2.Domestic International Tax Experts 3.International – International Tax Experts 3 Opportunities for Chartered Accountants in International Taxation T.P.Ostwal & Associates May 2013

4 T.P.Ostwal & Associates May 2013

5 Opportunities for Chartered Accountants in International Taxation T.P.Ostwal & Associates May Tax Exchange Information Agreements (TIEA) 2.Foreign Account Tax Compliance Act (FATCA) - US Regulation 3. Foreign Income for tax compliance requirements – Inadvertent trigger 4. Foreign Tax Credit Rules 5. WHT on payments Nokia case -an eye opener 6. General-Anti-Avoidance Rules (GAAR) 7. Direct Tax Code (DTC) 8. Controlled Foreign Corporation (CFC) 9. Thin Capitalization Regulation 10. White Paper on Black Money LIST OF TIEA’sTIEA’s

11. Organisation for Economic Co-operation and Development (OECD) 6  Beneficial Ownership  Safe Harbor Rules  Permanent Establishment Issues T.P.Ostwal & Associates Opportunities for Chartered Accountants in International Taxation May 2013

7 12. Emerging trend in Indian DTAAs T.P.Ostwal & Associates  LOB clause in Dividend Article  Collection of Tax on behalf of other states (countries)  Examination of tax payers on other countries by Tax Inspectors Opportunities for Chartered Accountants in International Taxation May 2013

13. Electronic Commerce 8 T.P.Ostwal & Associates Opportunities for Chartered Accountants in International Taxation May 2013

9T.P.Ostwal & Associates 14. Cloud Computing Opportunities for Chartered Accountants in International Taxation

15. Transfer Pricing May T.P.Ostwal & Associates Source: White paper on Black Money, Ministry of Finance, May 2012 Opportunities for Chartered Accountants in International Taxation

Issues and challenges in Transfer Pricing 11 T.P.Ostwal & Associates 1. Inter Company Accounts Payable / Accounts Receivable covered 2. Transfer of Intangible Properties and business restructuring 3. Corporate Guarantees, keep-well agreements and comfort letters 4. Lack of co-ordination between Transfer pricing policies and customs valuation for Reporting 5. Poor or missing Transfer Pricing procedures and controls within the Group 6. Incomplete Transfer Pricing documentation 7. Safe Harbor Rules 8. Domestic Transfer Pricing 9. UN Transfer Pricing Manual 10. APA Opportunities for Chartered Accountants in International Taxation May 2013

12 T.P.Ostwal & AssociatesMay 2013

13T.P.Ostwal & Associates List of TIEA’s signed by India 1.Argentina (Not yet in force) 2. Bermuda 3. Bahamas 4. Baharain 5. B ritish Virgin Islands 6. Cayman Islands 7. Guernsey 8. Isle of Man 9. Jersey 10. Liberia 11. Liechtenstein 12. Macao 13. Monaco 14. Sint Maarten (Not yet in force) BACK

14 T.P.Ostwal & Associates THANK YOU T. P. Ostwal & Associates CHARTERED ACCOUNTANTS 4 th Floor, Bharat House, 104 Mumbai Samachar Marg, fort, MUMBAI Tel No.: Fax No.: Mobile: May 2013