ICFAI University, Hyderabad organised interactive lectures on International Taxation and DTAA by D Manmohan, Vice President, ITAT and Transfer Pricing by J Sudhakar Reddy, Accountant Member, ITAT at the University campus on July 31. The lectures were moderated by J Mahender Reddy, Vice-Chancellor, ICFAI University.
Speaking on International Taxation and DTAA, D Manmohan emphasised on the importance of primary residence and source of income in determining jurisdiction of international taxation. He drew attention to the advent of digitalization and online services in further deepening the already complex subject of international taxation and further threw light on various models of Double Taxation Agreements, ‘Virtual Permanent Establishment’ and ‘Nexus based digital presence’ as new methodologies to plug loopholes in international taxation.
J Sudhakar, speaking on ‘Transfer Pricing’ emphasised on how related parties enter into various transactions to overcome tax laws. He also provided a bird’s eye view on various methods of transfer pricing and the importance of Functions, Assets & Risk (FAR) Analysis in Transfer Pricing. He also spoke about how the ‘range’ followed internationally and propounded by OECD, is being used to seek all available evidence to conclude what the arm’s length price would be.
The presentation was followed by an interactive question answer session, where the experts shared their views on the cases of Shell India on Capital transfers, and the Vodafone–Hutch tax issues.
Faculty members and students of The ICFAI University and academicians from the city participated in the event.