ONE YEAR ADVANCED DIPLOMA IN CORPORATE TAXATION
SEMESTER – I INTRODUCTION TO CORPORATE TAXATION
1.1.1 Foundations of Corporate Taxation and Corporate Tax Residency
Module I Constitutional Background of Corporate Taxation- Application of Income-tax Act beyond the territorial jurisdiction of India - Source and Residence basis – Overview of basic concepts and provisions relating to companies under the Income-tax Act, 1961
Module II Significance of Corporate Residency- Place of Incorporation- Place of effective Management-Comparative analysis of Control & Management Test with POEM-OECD Commentary- BEPS proposal- MLI recommendation-Unitary Taxation: Alternatives to C&M, POEM, POI- Brief overview- Residence-based Worldwide Taxation(RBWT)-Destination-based Cash Flow Taxation (DBCFT)-Common Consolidated Corporate Tax Base (CCCTB)
1.1.2 Taxation of Incomes of Companies Part I
Module I Determining tax base of corporate income- Taxable Income- Revenue Receipts and Capital Receipts- Imputed Income- House Property-Taxation of Windfalls- Receipt of Compensation towards damages, loss of agency-cancellation of indebtedness- Undisclosed incomes- Unexplained incomes, credits, investment, expenditure
Module II Losses and Expenditures – Revenue Expenditure and Capital Expenditure- Expenses and initial allowances- Amortisation of certain preliminary expenses
Additional deductions for companies in manufacturing acquiring and installing new assets- Depreciation- Expenditures due to commercial expediency- Disallowance of expenditures owing to transgression of laws, offences and penalties- Corporate Expenditure on CSR- Schedule III of CSR and Tax neutrality
Module III Minimum Corporate tax - Taxes on corporation Income tax-Minimum Alternate Tax (MAT)-Fringe Benefit Tax
1.1.3 Taxation of Incomes Companies Part II
Module I Taxation of Capital Gains Sec. 45, 47, Conversion of securities- Parents and Subsidiary provisions, valuation issues – Sec. 50CA and Sec. 56(2)(x)
Module II Income from Other Sources- Taxation of Gifts and Bequests- Sec. 56 and its impact on restructuring- Carry forward and set off of losses- Sec. 79
1.1.4 Tax Rebates and Tax Holidays for Companies
Module I Normative Justifications for Tax Holidays- Incentive to priority sectors- Geographical Development- Tax Competition- Various Modes of Tax Holidays with examples- Exemptions and Deductions- Deduction in Respect of Profits and Gains from industrial Undertakings or Enterprise Engaged in infrastructure Development (Sec. 80[IA)- Deduction in respect of certain income of Producer Companies(Sec.80PA) - Investment allowance- Special Economic Zones- Presumptive basis of taxes- Special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects- Judicial Interpretations of beneficial provisions in domestic law