Introduction to international corporate taxation: London, 16-18 April 2018
Apr 16-18
Completely revised course for 2017 on the application of international corporate tax law to cross-border transactions
This course is ideal for those new to international tax or who wish to fill any gaps in their knowledge. Covering the application of tax treaties to international transactions, anti-avoidance legislation and transfer pricing, the course is the perfect introduction for those new to corporate tax responsibilities.
And because its structure is based on the syllabus for paper 1 of the Advanced Diploma in International Taxation it is ideal preparation for those planning to take that exam. The compact nature of the course, just three days, makes it ideal for busy professionals and/or those travelling from outside the UK.
A recent course participant said of her success in the ADIT exam:
“The course held last November was fundamental to my success.”
The course also takes place in Winchester in late September, to address the growing importance internationally of businesses in the “M27 corridor”. Call +44 (0)1962 458058 or email deborah@djhinternationaltax.com for more details.
We have a new tutor for 2017, Johann Muller. His full biography is shown below but his wide range of experience working in practice as a lawyer, in-house for the world’s largest shipping company and, most recently, with a competent authority makes him ideal to teach the broadest range of participants from all backgrounds.
What is covered
- Basic principles of international tax law
- Double taxation conventions (DTCs)
- Transfer pricing and thin capitalisation rules
- International tax avoidance
- Miscellanous topics (indirect taxes; estate and gift taxes; cross-border mergers)
| General introduction | |
| Basic principles of international tax law | Jurisdiction to tax, including limits to tax jurisdiction under public international law, cross-border tax enforcement; taxes and tax systems; State practice in exercising tax jurisdiction; causes of international double taxation; methods of relief from double taxation; private international law and taxation; history of international tax law; EU law and international taxation; taxation and international human rights instruments; State responsibility in international taxation |
| Double taxation conventions (focusing on current version of OECD Model Tax Convention | Types of DTCs and their negotiation; DTCs and domestic law; format and structure of a DTC; approach to the application of a DTC; applying a DTC to a concrete scenario; interpretation of DTCs; provisions relating to the scope of a DTC; key definitional provisions; DTC provisions relating to businesses, individuals and investment income and gains; “other income” Article; limitation of benefit provisions; methods of eliminating double taxation; impact of non-discrimination Article; resolution of disputes; electronic commerce and DTCs |
| Transfer pricing and thin capitalisation rules | Determination of profits of branches and associated enterprises; State practice with respect to transfer pricing; transfer pricing and DTCs; Advanced Pricing Agreements; the OECD transfer pricing guidelines; State practice with respect to thin capitalisation; thin capitalisation legislation and DTCs |
| International tax avoidance | Tax havens; domestic law approaches to international tax avoidance; money laundering legislation; co-operation between revenue authorities; conventions for administrative assistance in tax administration; BEPS |
| Miscellaneous | Indirect taxes; cross-border mergers; estate and gift taxation |
Pricing for 3-day course: £1550 plus VAT at 20%
Cost includes tuition, full course documentation and refreshments including breakfast and lunch throughout.
Apr 05
Masterclass: The US Tax Cuts & Jobs Act 2018: corporate tax – 2 August 2018
Essential masterclass on the TCJA for those working with US corporate tax
£600 + VAT
Mar 26-29
In-depth US international corporate taxation: March 2019
Goes deeper into the detail of US corporate tax as it applies to international transactions for those already familiar with the principles of US tax
£1675 + VAT
