2-YEAR M.A. (INTERNATIONAL TAXATION)

(offered in collaboration with TAXMANN)

(Applicable from the batch admitted from the academic year 2023 – 2024)

About the Programme

The unprecedented proliferation of cross border transactions in a globalised and technically advanced world order essentially meant increased presence of entities doing business on foreign soil. While such transcending of political borders and even physical market places has brought opportunities and sources of tax revenues in the home country as well as the host country, it also poses its own set of challenges. Both domestic tax laws and DTAA regimes situated in the ‘brick and mortar’ model of doing business are found to be inadequate to capture the eccentric market players of the digital economy. An already existing problem further deepens with the on-going undercurrents between the Global North and South attempts to re-configure the existing principles and arrangements of international taxation.

Consequentially Double Tax Avoidance Agreements assume criticality in present time taxation scene for more reasons than just avoiding double-taxation. Today any understanding of the law and practice of domestic tax law is incomplete without appreciating the implications of DTAA. This programme offers a thorough comprehension of the international taxation and in-depth understanding of the related concepts and controversies of high relevance be it for policy, practice or academics.

This is a course that caters to an audience of learners including professionals, company executives, revenue authorities, faculties, researchers or students

Procedure for admission, duration and fee structure

 

Eligibility

a. Bachelor’s Degree or an equivalent Degree in any discipline from any recognized University; or

b. Candidates appearing for the final year examination of Graduation / Engineering are also eligible to apply.

c. Full Members of ICSI/ICAI/ICMAI

Admission Procedure

Direct Admission subject to fulfilment of the eligibility criteria.

Duration, Continuation and Termination

The duration of the programme is two years and the maximum period for completion of the programme is four years including the year of admission.

Every candidate admitted to the course shall pay the prescribed fees for the first year at the time of admission and the fee for the second year shall be paid at the beginning of the third semester. If a candidate is required to continue the course beyond the minimum duration because of his/her non-fulfillment of the prescribed requirements for the award of the M.A. Degree, he/she shall pay the Continuation Fee, as prescribed to continue their course after the minimum period.

The marks secured in the papers already appeared by the candidate shall be carried forward during the span of the eligibility for the programme.

After completion of the maximum period, if the candidate fails to fulfill all the requirements for the award of the M.A. Degree, the admission stands automatically cancelled. In such cases they need to enrol afresh for the programme.

Fee Structure

Course fee: Rs. 50,000/- p.a. (5% fee concession to the candidates belonging to SC / ST / PWD Category)

• Repeat examination / Supplementary Examination fee : Rs.500/- per paper / per project
• Continuation fee beyond the minimum duration of the course till the maximum period : Rs.5,000/- p.a.
• Re-evaluation Fee : Rs. 1,000/- per paper
• Boarding & Lodging charges at campus (subject to availability) during classes / exam will be extra as per the University Rules.
• Convocation fee will be charged separately as per the University Rules.

Note: If a candidate fails to submit the projects / assignments / case studies for the subjects offered in the relevant semester, then the candidate should pay the applicable repeat examination fee per subject for submission of the project / assignment / case study at a later date.

Note: The University reserves the right to revise the Fee structure from time to time

Course Structure

Subject Code	Subject	Maximum Marks	Credits
SEMESTER - I FOUNDATION OF INTERNATIONAL TAX TREATY
1.1.1	Understanding International Tax Treaties and Treaty Interpretation	100	6
1.1.2	Scope of Tax Treaties	100	5
1.1.3	Residence for Treaty Purposes	100	5
SEMESTER - II TAX TREATIES- PART I
1.2.4	Permanent Establishment and Allocation of Business Profits	100	6
1.2.5	Business Profits and Associated Enterprise and Transfer Pricing	100	6
1.2.6	Income from Immovable Property and Capital Gains	100	5
SEMESTER-III TAX TREATIES-PART II
2.3.7	Income from Equity and Debt Investment	100	5
2.3.8	Royalties and Fees for Technical Services	100	6
2.3.9	Methods of Elimination of Double Taxation and Most Favoured Nation Clause	100	5
Semester-IV CHALLENGES AND FUTURE OF TAX TREATIES
2.4.10	Mutual Agreement Procedure and Exchange of Information and Enforcement	100	6
2.4.11	Taxation of Digital Economy and Tax Avoidance	100	6
2.4.12	BEPS and MLIs and International Taxation- the way ahead	100	5

Conduct of the programme

The Master’s Programme will have four semesters. Each Semester will have Personal Contact Programme (PCP) sessions by the subject experts, followed by Online session where participants will work on the research projects / assignments / case studies and upload them on the dedicated web platform / submit them by email. The candidates can contact / communicate through email with the subject experts for queries, if any, on the concerned subject. Relevant course material will be uploaded on the website and can be accessed through their login id. The Self Learning Materials (Reading Materials) printed copies will be sent to the enrolled candidates.

PCP sessions will be conducted for six / seven days in each Semester at Hyderabad by the subject experts. Suggested reference guidance would be provided at the contact sessions. Each credit shall consist of three teaching hours. The recorded videos of the classes will be uploaded on the dedicated website. Attendance at the PCP is compulsory and the candidate should have atleast 75% attendance in the PCP to appear for the end semester examination. The learners are also expected to put in at least 30 hours of study for each credit.

Case study analysis / project / assignments will be part of the concerned subjects and will be discussed in onsite / online sessions. There will be one project / assignment / case study for each course. In total, a candidate must complete sixteen projects /assignments / case studies by the end of the programme.

The website will be the main delivery system in terms of updating information on the subject. The access to the website will be deactivated after the completion of the minimum duration and will be revived on the payment of the continuation fee.

Academic Calendar (Tentative)

Admission Process From February to June every year

SEMESTER I & III
S.NO.	Name of the Activity	Tentative Months
		From	To
1	Distribution of course material	August	September
2	Personal Contact Programme	October	November
3	Submission of Assignments/projects/case study	November	December
4	Examinations		December
5	Declaration of Results		February
6	Repeat Examinations	May	May

SEMESTER II & IV
S.NO.	Name of the Activity	Tentative Months
		From	To
1	Distribution of course material	January	February
2	Personal Contact Programme	February	March
3	Submission of Assignments/projects/case study	April	May
4	Examinations	May	June
5	Declaration of Results	July	August
6	Repeat Examinations		December

Note : The PCP Sessions (classes) will be conducted in blended mode (online / physical) at NALSAR University of Law, Hyderabad. However, the examinations will be conducted physically at Hyderabad only.

 

Evaluation Scheme & Award of M.A. Degree

Each paper shall carry 100 marks. The distribution of marks shall be as follows:

Assignment(s) / Project / Case Study :	30 Marks
End Semester Examination :	70 Marks

NOTE: No candidate will be permitted to appear for the End Semester Examination unless he / she has attended 75% in the programme specific Personal Contact Programme.

Award of Grades

The performance of all the candidates in all subjects shall be evaluated on a 10 point scale with corresponding grade values as mentioned below:

Percentage of Marks	Grade	Grade Value
90 and above	O+ (Exceptionally Outstanding)	10
85 – 89	O (Outstanding)	9
80 – 84	E+	8.5
75 – 79	E (Excellent)	8
70-74	A++	7.5
65-69	A+	7
60-64	A	6.5
55-59	B+	6
50-54	B (Pass)	5.5
Below 50	F(Fail)	0

The result will be declared as ‘W-withheld’ for all the candidates who appear for the examination and fail to submit the projects / assignments / case studies. Even if a candidate secures the minimum required marks, i.e, 50 in the end semester examination and fails to submit projects/assignments/case studies, the result will be declared as ‘W-withheld’. In both the cases, the candidates are required to register for the repeat examination and pay the requisite fee for submission of the projects / assignments / case studies.

Calculation of CGPA

Cumulative Grade Point Average (CGPA) is arrived at by dividing the sum of the products of Grade Values and the Credits in each subject by the total number of credits in all the subjects.

A candidate to be successful should obtain a minimum of 50% marks or the equivalent grade, i.e., B in every subject. A candidate who secures the minimum required 50% marks will not be declared passed until he/she submits the assignments/projects/case studies as prescribed. However, the candidate who fails to obtain the minimum grade (i.e., B) shall be given chance(s) to re-appear for the examination whenever the same is conducted till the completion of the maximum period, i.e., four years from the date of admission on payment of repeat / supplementary examination fee and the continuation fee as prescribed. No candidate who has cleared the subject by securing 50 marks or above is allowed to re-appear in the examination for improving the marks / grade.

Rounding off and Award of Grace Marks

In case a candidate obtains fractional marks, the fraction will be rounded off to the nearest whole number.

The Course Coordinator with the approval of the Director, DDE may add FIVE grace marks in total for all the subjects in a semester to enable a candidate to pass the examination. The said provision will not be applicable in case of re-evaluation and/or for improvement of grade.

Provided that under no circumstances, a candidate shall be granted more than five grace marks in a semester to be distributed in all subjects.

Award of the Master’s Degree

A candidate to be eligible for the award of the Master’s Degree, i.e., M.A. (International Taxation) should submit all the assignments / projects / case studies and should secure 50% marks or ‘B’ grade in all the subjects obtaining atleast CGPA 5.50 out of 10.00.

A candidate admitted to the program has to complete all the prescribed requirements within a maximum period of four years from and including the year of admission in order to be eligible for the award of the Master’s Degree.

Procedure for Re-counting / Re-evaluation

The candidates desiring of re-evaluation have to apply in writing along with the re-evaluation fee within 15 days from the date of declaration of results. On the receipt of the request for re-evaluation, the paper would be sent to subject expert other than the evaluator and the results of the same will be communicated within 45 days. A change in the original score shall be made only when, upon re-evaluation, the change is FIVE marks or more. The Re-evaluation result is final and there will be no further appeal to the same.

No candidate who has cleared the subject by securing 50 marks or above is allowed to re-appear in the examination or apply for re-evaluation for improving marks / grade.

The recounting of the paper would be done without collecting any fee but on the written request to the Director, DDE by the candidate. The change, if any, shall be incorporated accordingly.

Misconduct Rules

The Vice-Chancellor on the report and recommendation of the Course Co-ordinator can cancel the registration of a candidate and also debar them from examinations and further enrolment if he or she is found to be indulging in abusive, unruly behavior with the faculty or staff of the University. Such behavior will also include abusive mails, phone calls or defamatory tweets / posts / blogs etc.

The NALSAR University Academic Mis-Conduct Regulations, as approved by the Executive Council of the University will apply suitably for the candidates enrolled for this programme.

Refund of Fee in case of withdrawal of admission

a) In case of withdrawal within 15 days from the closure of the admission, 10% of the course fee paid shall be retained by the University towards administrative charges;

b) In respect of candidates who withdraw their candidature after 15 days from the closure of admission, total course fee paid by the candidates shall be retained by the University.

c) All other fee other than course fee, once paid is non-refundable.

Note: The University reserves the right to modify the admission process, fee structure, course structure, course content, the evaluation scheme and other Rules from time to time.

Course Structure

Subject Code	Subject	Maximum Marks	Credits
SEMESTER - I FOUNDATION OF INTERNATIONAL TAX TREATY
1.1.1	Understanding International Tax Treaties and its implications on Domestic Tax Laws	100	3
1.1.2	Interpretation of Tax Treaty	100	4
1.1.3	Scope of Tax Treaties	100	3
1.1.4	Residence for Treaty Purposes	100	5
SEMESTER - II TAX TREATIES- PART I
1.2.5	Permanent Establishment	100	5
1.2.6	Business Profits and Associated Enterprise	100	4
1.2.7	Transfer Pricing and Allocation of Business Profits	100	5
1.2.8	Income from Immovable Property and Capital Gains	100	4
SEMESTER-III TAX TREATIES-PART II
2.3.9	Income from Equity and Debt Investment	100	5
2.3.10	Royalties and Fees for Technical Services	100	5
2.3.11	Taxation of Digital Economy	100	4
2.3.12	Tax Avoidance	100	4
Semester-IV CHALLENGES AND FUTURE OF TAX TREATIES
2.4.13	Methods of Elimination of Double Taxation	100	5
2.4.14	Exchange of Information and Enforcement	100	4
2.4.15	Most Favoured Nation Clause and Mutual Agreement Procedure	100	5
2.4.16	BEPs, MLIs and Future of International Taxation- The way ahead	100	4