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Base Erosion and Profit Shifting (BEPS) » TR06

Base Erosion and Profit Shifting (BEPS)

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DateFormatDurationFees
03 Jun - 11 Jun, 2024Live Online7 Days$3147Register
16 Sep - 20 Sep, 2024Live Online5 Days$2250Register
09 Dec - 13 Dec, 2024Live Online5 Days$2250Register
DateVenueDurationFees
24 Jun - 12 Jul, 2024Nairobi15 Days$13500Register
02 Sep - 06 Sep, 2024Nairobi5 Days$4950Register
23 Dec - 27 Dec, 2024Dar Es Salam5 Days$4950Register

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Course Overview

Unlawful practices in recent times pertaining to taxation tend to misuse the ambiguity of various tax rules and Double Tax Treaties (DTTs). Base Erosion and Profit Shifting (BEPS) avoidance strategies enable large enterprises to minimise their tax burden, eroding government revenue bases by strategically transferring profits.

Lately, the frequency of BEPS has come under intensified scrutiny, particularly in high-tax territories. The idea behind BEPS is to close gaps in international taxation for companies that allegedly avoid taxation or reduce the tax burden in their home country by engaging in tax inversions.

This course explores the various action plans of Base Erosion and Profit Shifting, what they deal with, and how BEPS is applicable on tax planning structures that are embraced by large organisations today.

Why is this ‘Base Erosion and Profit Shifting (BEPS)’ course of particular importance? Most BEPS schemes end up in double nontaxation outcomes, where income is not taxed at all or at minimal rates, failing to display a firm’s honest fiscal position at the jurisdictional site of created value.

Accordingly, tax authorities and international bodies like the OECD are advancing changes to existing rules. The modifications aim to address weaknesses in the current global system.

This Zoe training course will empower you with the knowledge to gain an understanding of how the BEPS influences fiscal policy officials locally and internationally.

Course Objectives

Upon finishing this course effectively, participants will be able to:

  • Learn about different action plans for Base Erosion and Profit Shifting
  • Recognise the key provisions of each of the OECD Base Erosion and Profit Shifting Action Plans that address the weaknesses in the international tax framework governing cross border transactions
  • Distinguish the related suggestions requiring a shift by tax policymakers to reinstate faith in the system, guarantee that profits are taxed where economic activities take place and create truthful economic value
  • Discover the emergence of competing sets of international tax standards, and the replacement of the current consensus-based framework by unilateral measures
  • Assess action plans to provide countries with local and international tools that will better align rights to tax with economic activity

Training Methodology

This is an interactive training program and will consist of the following training approaches:

  • Lectures
  • Seminars & Presentations
  • Group Discussions
  • Assignments
  • Case Studies & Functional Exercises

Similar to all our courses, this program also follows the ‘Do-Review-Learn-Apply’ model.

Organisational Benefits

Companies who send in their employees to participate in this course can benefit in the following ways:

  • Obtain a customised and all-inclusive Base Erosion and Profit Shifting program with features best suited to address your organisation’s needs
  • Produce a detailed international Base Erosion and Profit Shifting profile for your organisation
  • Save on legal expenses risen due to Base Erosion and Profit Shifting violations
  • Ensure that your company is running with the most streamlined processes in Base Erosion and Profit Shifting
  • Employ the right people to ensure that the Base Erosion and Profit Shifting policies are implemented properly

Personal Benefits

The partakers of this course can benefit in the following ways:

  • Explain the factors that drive the need for Base Erosion and Profit Shifting, and understand the consequences of breaching these laws in a highly legalised world
  • Prevent your company from the probable issues faced due to improper Base Erosion and Profit Shifting management
  • Create strategies for implementing Base Erosion and Profit Shifting policies including specific tools and technologies, and then monitoring and training of these policies to build an effective Base Erosion and Profit Shifting compliance program
  • Benefit from the broad range of content created by leading tax experts from around the world

Who Should Attend?

This course would be suitable for:

  • Accountants
  • Tax advisers
  • General tax practitioners
  • Tax practitioners in advisory firms
  • Tax specialists in commercial and trade industries
  • Government officials
  • In-house tax directors/managers
  • Tax regulation bodies

Course Outline

MODULE 1: BACKGROUND

  • International Standards in Tax Sovereignty
  • Existing Domestic Law and Treaty Rules
  • Weaknesses That Create Opportunities For BEPS
  • Challenges for International Taxation

MODULE 2: OECD AND BEPS

  • History & Overview
  • What is the OECD?
  • The Problems with Taxation Laws and Avoidance Mechanisms
  • What is BEPS?
  • The BEPS Action Plan
  • The Effectiveness of the BEPS Action Plan Across Nations

MODULE 3: ADDRESSING THE TAX CHALLENGES OF THE DIGITAL ECONOMY

  • Practices That Artificially Segregate Taxable Income
  • The rationality of Corporate Income Taxation at the Global Level
  • Changing Business Models and Technological Developments

MODULE 4: NEUTRALISING HYBRIDS, CFCS, INTEREST DEDUCTIONS, AND TRANSPARENCY

  • Neutralise the Effects of Hybrid Mismatch Arrangements
  • Strengthen CFC Rules
  • Restrict Base Erosion Through Interest Deductions and Other Commercial Payments
  • Counteract Harmful Tax Practices More Efficiently

MODULE 5: TREATY SHOPPING, PERMANENT ESTABLISHMENTS, TRANSFER PRICING, MEASURING AND MONITORING BEPS

  • Averting the Granting of Treaty Benefits in Unfitting Circumstances
  • Stopping the Avoidance of Permanent Establishment Status
  • Aligning Transfer Pricing Outcomes with Value Creation
  • Measuring and Monitoring BEPS

MODULE 6: DISCLOSURE, DOCUMENTATION, DISPUTE RESOLUTION, MULTILATERAL INSTRUMENT, AND CURRENT DEVELOPMENTS

  • Necessitate Taxpayers to Divulge Aggressive Tax Planning Arrangements
  • Re-Examine Transfer Pricing Documentation
  • Make Dispute Resolution Mechanisms More Effective
  • Develop a Multilateral Instrument

MODULE 7: ACTION PLANS

  • Establishing International Coherence of Corporate Income Taxation
  • Reinstating the Full Effects and Benefits of International Standards
  • Neutralise the Effects of Hybrid Mismatch Arrangements
  • Guaranteeing Transparency While Promoting Increased Certainty and Predictability
  • Strengthen CFC Rules
  • The Need for A Prompt Implementation of The Measures
  • Prevent Treaty Abuse
  • Prevent the Artificial Avoidance of PE Status
  • Make Transfer Pricing Outcomes Consistent with Value Creation
    • Intangibles
    • Risks & Capital
    • Other High-Risk Transactions
  • Determine Methodologies to Gather and Analyse Data on BEPS And the Actions to Address It

MODULE 8: METHODOLOGY

  • A Comprehensive and Effective Process: Releasing The OECD/G20 BEPS
  • Project and Involving Developing Countries
  • Efficient Process Development
  • Consulting with Business and Civil Society

MODULE 9: CURRENT DEVELOPMENTS IN BEPS

  • S. Income Tax Recent Tax Legislation and BEPS
  • Recent Post BEPS Issuance Activity of the OECD
  • Recent Post BEPS Issuance Activity of the USA

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