CS Professional Advanced Tax Laws Classes
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CS Professional Paper 2 — Advanced Tax Laws
Advanced Tax Laws is a 100-mark paper that takes tax to the highest level in the CS curriculum. It covers Direct Tax at an international and planning level (DTAA, TP, GAAR, BEPS) and Indirect Tax at a compliance and adjudication level (GST assessment, refunds, anti-profiteering, Customs). For the November 2026 exam, Finance Act 2025 applies.
Advanced Direct Tax
- International taxation — Residency, source of income, double taxation concepts
- DTAA provisions — OECD/UN model articles: PE (Article 5), Business Profits (7), Dividends (10), Interest (11), Royalties (12), Capital Gains (13), Employment (15)
- Transfer Pricing — Arm's length standard, prescribed methods (CUP, RPM, CPM, TNMM, PSM), documentation (Master File, Local File, CbCR), APA (Advance Pricing Agreement) and MAP (Mutual Agreement Procedure)
- GAAR — Sections 95–102, impermissible avoidance arrangement, commercial substance test, consequences
- BEPS — Action Plan overview, MLI (Multilateral Instrument), India's MLI positions, BEPS Action 2 (hybrid mismatches), Action 13 (CbCR)
- Black Money Act 2015 — Provisions, penalties, prosecution
- Tax planning, avoidance, and evasion — Thin capitalisation, treaty shopping, anti-avoidance measures
Advanced Indirect Tax
- Complex GST scenarios — Multi-tier supply chain ITC, cross-border service taxability, OIDAR services
- GST Assessment and Audit — Section 65 (departmental audit), Section 66 (special audit by CA/CMA), scrutiny, best judgement assessment
- Demand and Recovery — Section 73 (non-fraud, 3-year limitation), Section 74 (fraud/suppression, 5-year limitation), show cause notice, adjudication
- Refunds — Zero-rated supply refunds, ITC refund for exporters, inverted duty structure, RFD process
- Appeals — GSTAT (when operational), High Court, Supreme Court; pre-deposit requirements
- Anti-Profiteering — Section 171, NAA/DGAP, profiteering computation methodology
- Customs Act 1962 — Valuation, classification, duty structure (BCD, CVD, IGST on imports), drawback
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