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Partial Income Exemption and Substance Requirements
INTRO AND AGENDA
Intro (2:37)
Course Agenda (2:15)
INCOME ELIGIBLE FOR THE PARTIAL INCOME EXEMPTION (PIE)
Income Eligible for the Partial Income Exemption (PIE) (2:50)
IMPLICATIONS OF PARTIAL INCOME EXEMPTION
Implications of Partial Income Exemption (12:42)
Case Study 1 - implications of Partial Income Exemption (11:11)
Case Study 2 - implications of Partial Income Exemption - Question (6:57)
Case Study 2 - implications of Partial Income Exemption - Answer (15:34)
FOREIGN SOURCE DIVIDEND AND PARTIAL INCOME EXEMPTION
Foreign Source Dividend and Partial Income Exemption (5:15)
Case Study 3 - Foreign Source Dividend and Partial Income Exemption - Question (3:58)
Case Study 3 - Foreign Source Dividend and Partial Income Exemption - Answer (4:51)
INTEREST INCOME AND PARTIAL INCOME EXEMPTION
Interest Income and Partial Income Exemption (1:00)
Case Study 4 - Interest Income and Partial Income Exemption - Question (6:21)
Case Study 4 - Interest Income and Partial Income Exemption - Answer (14:18)
PERMANENT ESTABLISHMENT AND PARTIAL INCOME EXEMPTION
Permanent Establishment and Partial Income Exemption (2:09)
Case Study 5 - Permanent Establishment and Partial Income Exemption - Question (5:52)
Case Study 5 - Permanent Establishment and Partial Income Exemption - Answer (22:47)
LEGISLATION ANALYSIS ON PARTIAL INCOME EXEMPTION
Legislation analysis on Partial Income Exemption (7:54)
SUBSTANCE CONDITIONS TO BENEFIT FROM PARTIAL INCOME EXEMPTION UNDER ITA
Substance conditions to benefit from Partial Income Exemption under ITA (10:58)
CORE INCOME GENERATING ACTIVITIES
Core Income Generating Activities (0:29)
INCOME TAX REGULATIONS - REG 23 D
Income Tax Regulations - Reg 23 D (16:14)
OUTSOURCED ACTIVITIES
Outsourced Activities (2:53)
STATEMENT OF PRACTICE - MRA
Statement of Practice - MRA (13:54)
WEIGHTED AVERAGE METHOD TO DETERMINE SUBSTANCE CONDITIONS
Weighted Average Method to determine substance conditions (10:43)
Outro (0:53)
Case Study 3 - Foreign Source Dividend and Partial Income Exemption - Question
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