Taxation of Non Residents

Topics Covered under CA Final International Taxation Elective Paper 6C, Module 2 – Taxation of Non Resident

• Introduction to Non-Resident Taxation
• Residential Status Section 6
  • Residential Status of an Individual
  • Residential Status of HUF
  • Residential Status of Company
• Place of Effective Management
• Special Provisions for Foreign Company said to be resident in India – Section 115 JH
• Scope of total income on the basis of Residential Status – Section 5
• Meaning of Income Received or Deemed to be Received
• Income Deemed to be received in India – Section 7
• Income deemed to accrue or arise in India – Section 9
  • Taxability of Offshore Funds
  • Income deemed to accrue or arise in India – Section 9 of Income Tax Act
  • Deemed Interest Income – Section 9(1)(v) of Income Tax Act
  • Section 9(1)(vi) of Income Tax Act – Deemed to accrue or arise of Royalty Income
  • Section 9(1)(vii) of Income Tax Act – Fee for Technical Services
• Section 10 of Income Tax Act – Exempt Income of Non Residents
• Presumptive Taxation for Non residents
  • Section 44B of Income Tax Act – Shipping Business of Non Residents
  • Section 172 of Income Tax Act
  • Section 44BB of Income Tax Act
  • Section 44BBA of Income tax act
  • Section 44BBB of Income Tax Act
  • Section 44c of Income Tax Act
  • Section 44DA of Income Tax Act
• Capital Gains – Section 45 of Income Tax Act
  • No Exemption u/s 10 on Urban Agricultural Land – Explanation 1 to Section 2(1A)
  • Short Term and Long Term Capital Assets
  • Section 47 of Income tax act – Transactions not regarded as transfer
  • Section 48 of Income Tax Act – Mode of Computation of Capital Gains
  • Section 111a of Income tax act
  • Section 112a of Income tax act
• Special Provisions Prescribed Under Chapter XII A of Income tax act
  • Section 115a of Income Tax Act
  • Section 115ab of Income tax act
  • Section 115AC of Income tax act
  • Section 115AD of Income tax act – Tax on Income of Foreign Institutional Investors
  • Tax on Non Resident Sportsmen or Sports association
• MAT on Foreign Companies
• Special provisions relating to conversion of India Branch of a Foreign Bank into a Subsidiary Company – Chapter XII BB of Income Tax
• Withholding tax on payment to Non Resident
• Miscellaneous Provisions for Non Residents