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Mentblue is dedicated to fostering the next generation of legal professionals. Mentblue’s programs are personally curated by co-founders Prafful Goyal, a former Principal Associate (7 years at CAM), and Ashutosh Singh, a former Senior Associate (4 years at CAM).
Drawing from their combined experience at top-tier law firm Cyril Amarchand Mangaldas, they ensure their courses are serious and practical. Mentblue connects aspirants with mentors who provide guidance rooted in the direct realities of elite legal practice.
About Course on International & Corporate Tax
The growing complexity of global business, cross-border transactions, and evolving tax regulations has created a strong demand for professionals skilled in international and corporate taxation.
This 6-week course on International & Corporate Tax equips law students and professionals with practical knowledge of tax treaties, transfer pricing, corporate tax structures, and dispute resolution. Taught by leading experts from top firms such as Khaitan & Co., Trilegal, and Cyril Amarchand Mangaldas, the program bridges academic learning with real-world legal practice in international tax.
Who can Attend?
Law students (including LLM students), graduates, academicians and practitioners.
Modules
Session 1: Introduction [Longer Session]
Part I: Principles of Interpretation
- Key principles of statutory interpretation for tax law (Strict interpretation of charging provisions, liberal interpretation for machinery and exemption provisions, harmonious interpretation in case of conflicting provisions, etc.).
- Key principles of tax treaty interpretation
- Stare decisis, and understanding ratio decidendi vs obiter dicta
- Introduction to research tools.
Part 2
- Brief walk/navigating through provisions under Income-tax Act, 1961 vis-à-vis Income-tax Act, 2025 (both herein referred as “IT Act” interchangeably), relevant to cross-border & international taxes.
- What categorises as international tax, such as interplay between IT Act and double taxation avoidance agreements (“DTAA”), tax residency (Incl. place of effective management (“POEM”), significant economic presence (“SEP”), & business connection), transfer pricing (“TP”), repatriation strategies, permanent establishments (“PE”), withholding taxes, anti-avoidance rules & base erosion & profit shifting (“BEPS”) I & II.
- The need of international tax lawyers in the rise of global capability centres, employment structures, offshore/onshore operations, reverse flips, financial & technological advancements etc.
Session 2: Corporate tax
- Introduction to key aspects of corporate taxation pertaining to business income, capital gains, dividends, interest, royalty, and fees for technical services (“FTS”).
- Understanding the key differences in taxation of a domestic company, limited liability partnership/partnership firm, and a trust, excluding deductions.
- Introduction to tax deducted at source & tax collected at source concepts.
- Brief introduction to the concept of incurring, carrying forward, and set off of tax losses along with explaining its relevance and importance.
- [Given the short amount of time, may consider to limit to fundamental concepts. Issues of tax return filing and PAN are more on the compliance / procedural side]
Session 3: Tax treaty & repatriations strategies
- Understanding the interplay of IT Act and DTAA. Overview of key principles concerning interpretation of tax treaties (i.e., balancing strict interpretation, liberal interpretation, and tax anti-avoidance).
- Understanding how to navigate through DTAA (Note: To include how to read and understand).
- Brief overview of key/commonly interpreted clauses of DTAA including capital gains, dividends, interest, royalty, FTS, and foreign tax credit under the IT Act vis-à-vis the DTAA.
Session 4: Tax residency
- Understanding tax residency laws pertaining to corporates and individuals.
- Understanding the concepts of POEM, SEP and business connection.
- Understanding the tax implications for a foreign company along with key choices influencing corporate structure (Eg: setting up branch vs. subsidiary vs. joint venture vs. licensing rights and know-how).
- Understanding and drawing of structures.
Session 5: PE Risk
- Understanding PE concept under DTAA (fixed place PE, service PE, and dependent agency PE) and its relevance from operations & employment structures perspective.
- Introduction to key case laws.
- Brief discussion on recent updates under OECD 2025 and/or NITI Aayog report.
Session 6: Related party transactions
- Understanding concept of arm’s length price (ALP), associated enterprise (AE) and FAR analysis.
- Introduction to TP methods such as comparable uncontrolled price (CUP), resale price, and transactional net margin method (TNMM).
- Introduction to safe harbour rules, block assessments, and advance pricing agreements (APAs).
Session 7: M&A tax
Introduction to tax due-diligences
(Note: To include brief overview of what aspects under taxation is covered)
Session 8: Overview of Tax anti-avoidance rules
- Brief history of judicial anti-avoidance rules, along with Supreme Court’s Tiger Global ruling
- Introduction to multi-lateral instruments(MLI), general anti-avoidance rules (GAAR) vs. principal purpose test (PPT).
- Introduction to BEPS II (Pillar 1 and Pillar 2)
Session 9: Dispute resolution
- Introduction to types of assessments.
- Brief understanding of the timelines, chronology of the notices & orders and stages of tax litigation vis-à-vis the judicial/quasi-judicial adjudication.
Session 10: Way forward & career path
- Understanding the role among law firm, boutique firm, Big 4 and litigation practice.
- How to technically prepared, build resume & approach opportunities.
Faculties
- Ms. Bijal Ajinkya, Partner, Khaitan & Co.
- Ms. Aditi Goyal, Partner, Trilegal
- Mr. Rahul Jain, Partner, Khaitan & Co.
- Mr. Bipluv Jhingan, Principal Associate, Cyril Amarchand Mangaldas
- Mr. Hardeep Singh Chawla, Advocate
- Mr. Anuraag Bukkapatnaam, Associate, Khaitan & Co.
- Mr. DR Shashank, Associate, Cyril Amarchand Mangaldas
Duration
Course Duration: 6 Weeks
Classes will be held only on weekends (11 AM to 12PM). Recordings will be given from missed sessions.
Perks
- Weekend sessions with fixed timings
- Live and interactive sessions with doubt-clearing options
- Learn from the top industry experts
- A certificate on completion of the course to show your expertise
- Get access to recorded video lectures
- Practical assignments
Certification
Upon completion of the assignment, participants will receive an e-certificate that can be downloaded and printed for records.
Last Date of Enrolment
21 March
Course Fees
Rs 5999
After LawBhoomi Discount (Rs 600 off): Rs 5,399.00
Enrolment Procedure
Click Here to Enrol.
Note: LawBhoomi will only provide support for courses that you register for through the links on our platform. Registrations made through other links are not eligible for support. For any assistance, write to: [email protected]
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