Several corporates in India (MNCs as well as Indian Groups) make large payments to foreign entities. Determining TDS (also known as withholding tax or WHT) implications on these payments is critical, before making remittance outside India. A large majority of these payments are towards services or use of assets/intellectual property. These could be taxable in India, as royalty or Fees for Technical Services (FTS). The tax implications on royalty/FTS payments are relevant since in many such contracts, taxes are borne by Indian payer.

In recent years, scope of taxation of royalties and FTS under Indian Income Tax Act has been considerably enlarged (eg. various amendments to Sec 9). There has been considerable Indian juris-prudence on treaty interpretation principles. The increase in tax rate on royalty/FTS to 25% (if treaty relief is not available), will also create considerable tax impact.

Every taxpayer needs to obtain a certificate from CA confirming WHT implications. IT Department too has increased its focus and is closely monitoring foreign remittances, with online submission of CA certificates coupled with increased interaction with the Bankers. These changes require Indian Businesses (local as well MNCs) to have a greater focus on compliance. Managing the internal process & ensuring proactive involvement of tax team in business/contracts is also becoming critical.

With an aim to provide the practical insight, Wolters Kluwer (CCH India) & Taxsutra are organizing a two day focused workshop on tax implications relating to "Royalty and FTS Payments", in New Delhi on 20th & 21st February, 2014. The workshop intends to cover all the aspects of domestic & treaty law and practical aspects. The workshop will be conducted by experienced professionals with rich experience of consulting and industry.

Abhishek Chawla, Head of Tax, Xerox	Sanjiv Chaudhary, Partner, BSR & Company
Aseem Chawla, Partner, MPC Legal	Sujit Parakh, Director, Deloitte
Parul Jain , Principal, BMR Legal	Sumeet Hemkar, Director, BMR Advisors
Rupesh Jain, Partner, Vaish Associates Advocates

Domestic tax definitions of royalty & FTS taxation Treaty concepts under DTAA and other relevant treaty articles Taxation of special transactions like software, lease line, equipment Important concepts like TRC, Beneficial Ownership, MFN clauses

Key compliance in foreign remittances, PAN & computation issues Case studies and in-depth analysis of rulings Managing foreign payments - internal process, contractual aspects and risks

FOR REGISTRATION AND GROUP DISCOUNTS Rajni Dhingra Phone: +91-9811730211 Email: rajni.dhingra@wolterskluwer.com   Sneha Bisht Phone: 0124-4960968 Email: sneha.bisht@wolterskluwer.com

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