Description
Taxmann International Taxation Ready Reckoner 3rd Edition 2025 by Daksha Baxi, Surajkumar Shetty
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 3rd 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