Digital Interactive Learning for Professional Firms

Digital Interactive Learningfor Law andTax Practices

Structured micro concepts built for working professionals, applied as they are learned, a complete learning loop in minutes

Live examples below Indirect transferTreaty rate comparisonRun them yourself
Experience the Demos What it is
8 WeeksA typical pilot
2Sample Journeys
International Taxation + Foreign Investment & DTAAs
1Custom Build
Any topic your firm selects
YourFirm
White labelled to your identity
What this is

Built for professional judgement

Structure

  • Short micro concepts, each self-contained
  • Structured learning path, one concept at a time
  • Asynchronous and self-paced, white labelled to your firm

How it teaches

  • Interactivity on every screen
  • Active learning, the concept is applied as it is learned
  • A closed loop, learn, apply, decide, get feedback

Design basis

  • Learning experience design built for professionals
  • Andragogy, how working adults actually learn
  • Learning science, spacing, retrieval and application

Who it serves

  • Newer professionals strengthen their fundamentals
  • Experienced professionals refresh the concepts as the law now stands
  • Both alongside live work and senior guidance
Sample journeys

Two existing journeys, shown here as a sample of the format, every concept carries a verbatim source box, cross-referenced to the corresponding 1961 Act provision

Journey 01

International Taxation

A structured current-law refresh across the domestic international-tax framework, built to help lawyers revisit key provisions, connect cross-border issues and spot transaction implications quickly

Act-first diagnostic frameworkResidence & POEM Business connection & SEPRoyalty & FTS Interest, dividends & shareholder flowsCapital gains & indirect transfer Withholding & treaty documentationTransfer pricing & outbound issues
View full journey coverage

Module 1 · Act-First Diagnostic Framework

  • Act-first, treaty-aware analysis
  • Sections 5-9 source workflow
  • Income-tax Act, 2025 reference discipline
  • Characterisation before rate selection

Module 2 · Residence, POEM & Outbound Structures

  • Residence and scope
  • POEM statutory test
  • POEM evidence and annual defence
  • Outbound branch vs. foreign subsidiary
  • POEM risk

Module 3 · Business Connection & SEP

  • Domestic-law business connection vs. treaty PE
  • Agency and principal patterns
  • Dependent-agent type fact patterns
  • Stock and delivery patterns
  • Significant Economic Presence, prescribed thresholds
  • Exclusions and attribution
  • Eligible fund manager safe harbour

Module 4 · Royalty

  • Royalty source rule and definition
  • Contract signals
  • Software / SaaS domestic-law treatment
  • Domestic law vs. treaty boundary
  • Royalty rates and effectively connected income

Module 5 · Fees for Technical Services

  • FTS definition, source rule and exclusions
  • Resident-payer overseas-use carve-out
  • Reimbursements and cost recharges
  • Treaty "make available" awareness

Module 6 · Interest, Dividends & Shareholder Flows

  • Interest source rule and domestic rate starting point
  • Thin capitalisation
  • Dividend source and domestic rate mechanics
  • Buy-back, liquidation, shareholder-flow cautions

Module 7 · Capital Gains & Indirect Transfer

  • Direct transfer of Indian-situated assets
  • Indirect transfer, substantial-value test
  • Safe-harbour concepts
  • Buyer withholding and transaction protection

Module 8 · Equalisation Levy & Digital Tax

  • Historical Equalisation Levy framework
  • Legacy / open-year EL exposure
  • Post-EL digital-tax analysis through ordinary source rules

Module 9 · Non-Resident Withholding & Treaty Documentation

  • Non-resident withholding and timing
  • Domestic rate framework
  • Certificate and default mechanics
  • Remittance forms and process
  • Treaty-access documentation and withholding memo discipline

Module 10 · Transfer Pricing, Regulatory Layers & Outbound Repatriation

  • Transfer-pricing issue spotting, TP documentation
  • Safe harbour, APA, secondary adjustment
  • Adjacent FEMA / FDI / GST flags
  • Outbound repatriation, foreign dividends, POEM control implications

Module 11 · Integrated Cross-Border Capstone

  • Integrated cross-border transaction memo
  • Issue spotting across multiple international-tax decision zones
  • Structured advisory output
Journey 02
Unlocks after International Taxation

Foreign Investment & DTAAs

Builds on the International Taxation refresh and applies the foreign-investor and treaty lens to entry, income streams, treaty entitlement, anti-abuse rules, PE, capital gains and transaction structuring

FDI / FPI / debt entry routesFPI vs. non-FPI treatment Treaty reading frameworkTreaty entitlement Dividend / interestCapital gains Royalty / FTSBusiness profits / PEMLI & anti-abuse
View full journey coverage

Part 1 · Foreign-Investor Entry Routes

  • FDI, FPI, debt
  • FPI vs. non-FPI tax distinction

Part 2 · Charging Framework & Income Streams

  • Sections 4, 5 and 9 framework
  • Domestic-law charging analysis
  • Domestic rates reference
  • Where FPI and non-FPI regimes differ

Part 3 · Indirect Transfer

  • Foreign-share sale triggering Indian tax
  • Substantial-value / two-threshold test
  • Specified date, accounting period, FMV mechanics
  • India-attributable income, safe harbours
  • Reporting consequences, treaty interaction

Part 4A · Eight-Step Treaty Reading Sequence

  • Treaty anchor, source pack, residence
  • Characterisation, operative treaty words
  • PE bridge, anti-abuse, advisory output

Part 4B · Treaty Entitlement & Income Articles

  • Treaty entitlement tests, TRC and procedural documentation
  • Beneficial ownership, LOB, PPT
  • Dividend, interest, capital gains, royalty and FTS under DTAA
  • Make-available test where treaty-specific
  • Business income and Permanent Establishment

Part 5 · MLI

  • How the Multilateral Instrument modifies treaties
  • Key MLI provisions
  • Principal Purpose Test, treaty anti-abuse interaction

Part 5B · Integrated Case Simulation

  • Financing, exit, offshore layer
  • Domestic vs. treaty withholding
  • Thin-capitalisation implications
  • Capital-gains / Article 13 analysis
  • Indirect-transfer threshold analysis
  • Integrated advisory decision-making

Part 6 · Reporting

  • ITR filing, remittance reporting
  • Indirect-transfer reporting
  • Course synthesis and summary

Part 7 · Senior Advisor Sandbox

  • Multi-issue client review, issue spotting
  • Treaty entitlement, anti-abuse
  • PE and income-stream analysis, reporting
  • Conclusion drafting
Experience it

One live sample from every topic

Six topics, six samples, click any one and work it yourself

Basics of Income Tax

Person, assessee and tax year, in one map

The four foundational definitions every other module builds on, worked as one connected screen

Foundational conceptsInteractive map
International Taxation

Equalisation levy, then the digital-tax test that replaced it

Work through both frameworks and see exactly where the old regime ends and the current one begins

Two frameworksTimeline test
Capital Gains

Four disposals, 75 seconds, no going back

A timed desk challenge, classify holding period and rate correctly under pressure, exactly as the real call feels

Timed challengeScored live
FEMA

Two ceilings, computed independently

The LRS limit and the TCS rule do not move together, this walks through why staying under one does not zero out the other

Two-layer testStep-by-step
Mergers and Demergers

Four structures, before lunch, 120 seconds

Absorption or new company, forward or reverse, and which route skips the NCLT after the 2025 amendment

Timed challengeSix checkpoints
Foreign Investment & DTAAs

When an offshore share sale can still create an Indian tax exposure

Work the indirect transfer two-threshold test end to end, the way an advisor would

Two-threshold testSafe harbours
Built with your firm

One custom build, your expertise turned into capability

Your firm selects one capability or topic, then we work with your nominated SME to structure the knowledge, judgement points and application context, build the experience and validate it before launch

01

Your firm chooses

Any relevant topic or capability

02

SME co-creation

Structuring the agreed knowledge

03

Learning design

Architecture for the experience

04

Interactive build

Development of the experience

05

Your firm validates

SME review and sign-off

06

Pilot launch

Deployed within the 8 weeks

One custom experienceOne agreed topic One SME discovery / scoping interactionOne validation / review cycle Reasonable corrections
Scope of Services

What's included

Existing journeys

  • International Taxation
  • Foreign Investment & DTAAs
  • Current interactive exercises and application checks

Custom build

  • One topic your firm selects
  • SME scoping
  • Learning architecture
  • One interactive digital learning experience
  • One SME review / validation cycle
  • Reasonable corrections
  • Pilot deployment

Pilot delivery

  • Participant setup and access
  • Launch support
  • Feedback collection
  • Available completion / application observations

Close-out

  • Concise findings
  • Engagement / feedback observations
  • Areas for reinforcement or refresh
  • Recommendations for next step

Pilot scope · The journeys cover the law only, the statute, rules and treaty framework, as foundational capability
Firm proprietary knowledge, judicial precedents and advanced technical positions sit outside this scope, these can be designed after the pilot as your firm requires

What I offer

Four ways to work together

01

Pilot Program

An 8-week trial, two existing journeys plus one custom build, so your firm can test the format before committing further

02

Custom Build

One capability turned into an interactive experience, scoped with your SME, built and validated end to end

03

Full Curriculum Licence

The existing journeys, licensed and white labelled for your firm, deployed to your learners directly

04

Ongoing Capability Building

New journeys added over time, Capital Gains, Mergers and Demergers, Share Transfers, Buy-backs, Capital Reduction, FEMA, and any topic your firm needs

Let's talk

See what a pilot would look like for your firm

Commercial terms are shaped around what works best for your firm, nothing is fixed until we have spoken

Talk to me