TAXMANN – INTERNATIONAL TAXATION READY RECKONER BY CA DAKSHA BAXI -Updated Finance Act 2025

International Taxation Ready Reckoner presents a lucid, all-encompassing reference for readers. Authored by two leading experts in the field—this book incorporates the latest amendments brought about by the Finance Act 2025. It simplifies complex cross-border tax concepts, guiding readers through intricate regulations, bilateral tax treaties, and procedural requirements. With practical examples, case studies, and up-to-date judicial precedents, this Ready Reckoner ensures that readers can advise and comply with India’s ever-evolving international tax landscape.

This book is intended for the following audience:

• Tax & Legal Professionals – Chartered Accountants, tax consultants, legal advisors, and in-house counsels who deal with international taxation and cross-border transactions
• Corporate Executives & Finance Teams – CFOs, finance managers, and corporate tax departments responsible for ensuring tax compliance, structuring overseas investments, and evaluating cross-border business arrangements
• Academics & Students – Faculty, researchers, and advanced students specialising in international taxation, seeking practical insights and practical applications
• Entrepreneurs & SMEs – Business owners expanding internationally who need a straightforward, professional reference to navigate India’s international tax provisions

The Present Publication is the 3^rd Edition, amended by the Finance Act 2025. This book has been authored by CA. Daksha Baxi & Adv. Surajkumar Shetty, with the following noteworthy features:

• [Amended by the Finance Act 2025] Incorporates all legislative updates effective from the latest Finance Act, ensuring readers remain current with recent changes
• [Authoritative Guidance] Written by highly acclaimed tax experts recognised by global legal rankings
• [Practical Insights & Case Studies] Illustrates practical transactions and solutions, culminating in a comprehensive case study applying the rules and concepts explained
• [Step-by-step Explanations] Offers clarity on understanding the interplay between the Indian Income-tax Act 1961, Double Taxation Avoidance Agreements (DTAAs), and OECD/UN model conventions
• [Useful Tools & Aids] Contains ready reckoners, tabular comparisons, and examples to simplify complex topics like Permanent Establishment, Transfer Pricing, GAAR, etc.
• [Latest Judicial Precedents] In-depth discussion of landmark Indian and international rulings, enabling readers to strategise with the most recent case laws
• [Practical Compliance Checklist] Guides readers on obtaining a Permanent Account Number (PAN), Withholding Tax (TDS) compliance, return filing, Transfer Pricing documentation, and other procedural mandates

The coverage of the book is as follows:

• Foundational Concepts
  • Residential status determination (individuals, corporates, other entities)
  • Scope of income and deemed accrual principles
• Treaty Analysis
  • Key DTAA articles and interpretation
  • Most Favoured Nation (MFN) clauses, tie-breaker rules, and OECD/UN model commentary
• Setting Up in India
  • Business structures: subsidiaries, liaison offices, branch offices
  • Valuation provisions, anti-avoidance measures on share premium
• Taxation of Various Income Streams
  • Business income (Permanent Establishment, attribution of profits)
  • Dividend, interest, royalty, and fees for technical services
  • Capital gains, including indirect transfer of Indian assets
  • Employment income (including ESOPs for globally mobile employees)
  • Special regimes for NRIs, Foreign Portfolio Investors (FPIs), AIFs, REITs, InvITs, etc.
• Transfer Pricing Regulations
  • Arm’s length price determination methods, safe harbour rules, Advance Pricing Agreements (APAs), secondary adjustments
• Business Reorganisations & Exits
  • Tax-neutral amalgamation, demerger conditions, liquidation aspects, set-off and carry-forward of losses
• Dispute Resolution & Compliance
  • Assessments, appeals, DRP, Mutual Agreement Procedure (MAP), Authority for Advance Rulings (AAR)
  • GAAR provisions, how and when they apply
  • Withholding tax obligations, TDS/TCS rates, payment procedures
• Case Study
  • An extensive, end-to-end illustration combining multiple cross-border tax scenarios, from structuring to compliance

The structure of the book is as follows:

• Logical Progression – Starts with fundamental concepts of residency and the broad framework of international taxation, then progresses through specific income types, compliance measures, and dispute resolution avenues
• Chapter-wise Explanation – Each chapter addresses a distinct segment—e.g., Taxation of Dividends, Taxation of Royalties, Transfer Pricing, etc.—allowing readers to locate relevant material instantly
• Practice-oriented Approach – Every chapter includes practical examples, references to judicial rulings, and frequently encountered Q&A
• Dedicated Case Study – Concludes with a comprehensive scenario tying all concepts together, serving as a blueprint for real-world advisory and compliance scenarios
• Appendices – Relevant forms, statutory references, TDS/TCS rate charts, and a glossary of technical terms for quick lookup