Bharat’s Direct Tax Laws & International Taxation (A.Y. 2026-2027) (Module 4) (Paper 4 Group 2) (CA Final) by CA. Arvind Tuli for May 2026 Exam – 18th Edition 2026.

Bharat’s Direct Tax Laws & International Taxation (A.Y. 2026-2027) (Module 4) (Paper 4 Group 2) (CA Final) by CA. Arvind Tuli for May 2026 Exam – 18th Edition 2026.

About Direct Tax Laws & International Taxation for CA Final

Module 4 of CA Arvind Tuli’s renowned “Conceptual Clarity” series is dedicated exclusively to International Taxation. In the CA Final Direct Tax paper, International Tax is the most scoring section if understood conceptually. This book moves beyond rote memorization of sections and focuses on the logic of cross-border taxation, using Tuli Sir’s signature “Handwritten Notes” and flowcharts to simplify complex treaties and transfer pricing regulations.

Whether you are struggling with the calculation of Arm’s Length Price or decoding the nuances of DTAA, this module provides the visual tools and practical examples you need to master the subject.

What is Inside Module 4?

This volume covers the entire gamut of International Taxation (Chapter 1 to 8 of the International Tax syllabus):

• Transfer Pricing (TP): A complete breakdown of Associated Enterprises (AEs), International Transactions, and the computation of Arm’s Length Price (ALP) using various methods (CUP, RPM, CPM, PSM, TNMM).

• Non-Resident Taxation: Detailed analysis of Section 9 (Income deemed to accrue or arise in India), Business Connection, and the concept of Significant Economic Presence (SEP).

• Double Taxation Avoidance Agreements (DTAA): Explains how to read and apply tax treaties (Section 90/90A/91) to claim relief and avoid double taxation.

• Advance Pricing Agreements (APA): The procedure for rollback provisions and Safe Harbour Rules.

• Base Erosion & Profit Shifting (BEPS): Concepts of BEPS Action Plans and the Multilateral Instrument (MLI).

• Digital Taxation: In-depth coverage of the Equalization Levy (the “Google Tax”) on e-commerce operators.

• Model Tax Conventions: A comparative overview of the OECD vs. UN Models.

• General Anti-Avoidance Rules (GAAR): When and how GAAR is invoked in international structures.

Why Choose CA Arvind Tuli’s Module 4?

• “Handwritten” Summary Charts: The book features Tuli Sir’s famous handwritten mind maps. These charts summarize entire chapters (like Transfer Pricing methods) on single pages, which is invaluable for last-day revision.

• Logic-Based Learning: Instead of just stating the law, the book explains the intent behind provisions (e.g., why Secondary Adjustment exists), helping you tackle case-study-based MCQs.

• Practical Illustrations: International Tax is mathematical. This module is packed with solved problems for calculating the tax liability of foreign companies and non-residents.

• Exam-Oriented Keywords: The text highlights specific technical terms and phrases that examiners look for in your answer script to award full marks.

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