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Course Overview

International tax planning strategies of multinationals in these recent years have become a popular topic of discussion. Trade conditions and taxes are at the core of many business assessments and in a world of global expansions, having knowledge of only domestic tax laws is insufficient to ensure success.

This Masterclass in International Taxation Law course provides its participants with the means to become completely informed in the discussions of international taxation laws by describing the fundamentals and procedures of international tax law, as well as tackling current incidents and the moral characteristics of tax preparation.

This International Taxation Law course consists of an interactive curriculum including a series of lectures, each focusing on a specific aspect of international taxation, particularly pertaining to double taxation treaties and their application in practice.

The course is designed for participants who already have a good knowledge of international tax law but who wish to obtain a more in-depth understanding of latest developments in topical international tax law disputes, and how they influence the use of double taxation treaties.

This Masterclass in International Taxation Law program will also focus on how to utilise the remaining tax planning opportunities and spot potential safe harbours. This masterclass has been specially tailored to the practical needs of both tax authorities and tax finance professionals working in a variety of industrial and service sectors.

What will this ‘Masterclass in International Taxation Law’ course provide me? This program offers access to an international faculty with state-of-the-art knowledge in the field and experience from working with the courts and international legal institutions.

It discusses a unique combination of specialist courses with special focus on international taxation law. This International Taxation Law course has been devised to meet the pressures of the market for cutting-edge expertise on multi-jurisdictional legal matters.

This Zoe training course will empower you with knowledge in both the practical and theoretical aspects of trade and tax law.

Course Objectives

Upon completing this International Taxation Law course successfully, participants will study:

  • Planning taxes in light of the latest international case laws
  • Dealing with the impact of tax anti-avoidance measures
  • Managing substance to dismantle anti-avoidance tools – how to get the right level of substance
  • Setting up taxation structures to effectively plan indirect transfers of real estate
  • Recent case law and domestic law developments concerning anti-abuse measures from around the globe

Training Methodology

This is a collaborative International Taxation Law training program and will consist of the following training methods:

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

Similar to all our programs, this curriculum also adheres to the ‘Do-Review-Learn-Apply’ model.

Organisational Benefits

Business institutions who send in their employees to take part in this course can gain in the following ways:

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

Personal Benefits

Professionals who participate in this Masterclass in International Taxation Law course can benefit in the following ways:

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

Who Should Attend?

This Masterclass in International Taxation Law training 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

Course Outline

MODULE 1: INTERNATIONAL TAX PLANNING – BASE CASE

  • The Debate
  • Background & key stakeholders
  • The OECD & the EU
  • Introduction base case
  • Optional: Introduction to symbols
  • Interview with Prof. Dr Kees van Raad
  • Introduction to BEPS

MODULE 2: FUNDAMENTALS OF TAX TREATIES

  • The international tax environment
  • Double tax relief
  • How tax treaties operate
  • Responsibility and expansion of model treaties and commentaries
  • The making of tax treaties
  • Eligibility to treaty benefits
  • Interpretation and dispute resolution

MODULE 3: FUNDAMENTALS OF VALUE ADDED TAX

  • Introduction to value added tax
  • Essential attributes of taxable supplies – goods and services
  • Taxable persons
  • Taxable amount – VAT rates and exemptions
  • Place of supply – Goods
  • Place of supply – Services
  • Deduction and recovery of input tax
  • Administrative elements of VAT

MODULE 4: DESIGN OF CORPORATE TAX LAW SYSTEMS

  • Introduction to Corporate Income Tax
  • Tax chargeable base & rate
  • Tax chargeable base & rate: tax havens & preferential tax regimes
  • Tax chargeable base & rate: intercompany dividends & capital gains
  • Taxation of corporate groups
  • Withholding Tax
  • Interview with Prof. Dr Kees van Raad
  • Interest deductions and other financial payments

MODULE 5: PRINCIPLES OF INTERNATIONAL TAXATION & TAX TREATIES

  • Controlled foreign company regimes
  • Hybrid mismatches
  • Introduction to international tax law
  • Double taxation
  • Distributive rules
  • OECD & BEPS
  • Interview with Prof. Dr Kees van Raad
  • Hybrid mismatch arrangements & preventing treaty abuse

MODULE 6: INTERNATIONAL TAX PLANNING

  • Introduction to international tax planning
  • Formal aspects of tax planning
  • Substantive aspects of tax planning
  • Tax structuring of holding and financing activities
  • Tax structuring of manufacturing and distribution activities
  • Tax planning for intangible property

MODULE 7: TRANSFER PRICING

  • What is transfer pricing?
  • Why is it important?
  • The arm’s length principle: legal framework
  • Traditional transaction methods
  • Transactional profit methods
  • Business restructuring
  • Apple case
  • Outro – Transfer Pricing
  • Interview with Prof. Dr Kees van Raad
  • Transfer pricing of intangibles

MODULE 8: EUROPEAN UNION LAW & FISCAL STATE AID

  • Introduction EU & corporate tax planning
  • Tax competition & tax planning
  • Introduction to state aid law
  • State aid & tax planning
  • Adjustment P/S Directive
  • EU Free Movement Law (I)
  • EU Free Movement Law (II)
  • Interview with Prof. Dr Kees van Raad

MODULE 9: DOUBLE TAXATION RELIEF

  • Introduction to double taxation relief (DTR)
  • Exemption
  • Credit – creditable amount
  • Credit – credit limits and excess credits
  • Deduction
  • Income computation
  • Losses
  • Legal basis of DTR
  • Persons eligible for DTR
  • Foreign income eligible for DTR
  • Taxes eligible for DTR
  • Problem areas

MODULE 10: TAX PLANNING & ETHICAL DIMENSIONS

  • Introduction on tax planning & ethical dimensions
  • Interview with Pascal Saint-Amans
  • Interview with Tanja Bender
  • Interview with Robert Stack
  • Interview with Marlies de Ruiter
  • Interview with Giuseppe van der Helm
  • Interview with Paul Morton
  • Interview with Antonio Russo
  • Interview with Prof. Dr Kees van Raad
  • Outro – tax planning & ethical dimensions
  • BEPS & developing countries
Online Courses
Note
Customized Schedule is available for all courses irrespective of dates on the Calendar. Please get in touch with us for details.
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