International corporate taxation: Four one-day masterclasses in London, 17-20 September 2018
Sep 17-20
Completely revised and restructured course on the application of international corporate tax law to cross-border transactions
The course has been restructured into four self-contained one-day masterclasses covering the key elements of international tax practice. Together the course will form ideal preparation for the Advanced Diploma in International Taxation, with the fourth day covering case law and past exam questions and practice. The complete course is ideal for those new to international tax and flexible for those who just wish to fill gaps in their knowledge or revise its application to sitting an exam!
Covering the application of tax treaties to international transactions, anti-avoidance legislation and transfer pricing, the full course is the perfect introduction for those new to corporate tax responsibilities whether in-house or in professional practice.
The compact nature of the course makes it ideal for busy professionals and/or those travelling from outside the UK.
Call +44 (0)1962 458058 or email deborah@djhinternationaltax.com for more details.
Your course tutor is 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
- Day 1: Jurisdiction to tax, enforcement and anti-avoidance
- Day 2: Double taxation conventions (DTCs)
- Day 3: Transfer pricing and thin capitalisation rules
- Day 4: Case law review; consideration and practice of past exam questions
| Day 1 | Jurisdiction to tax, enforcement and anti-avoidance |
| 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; tax havens; domestic law approaches to international tax avoidance; money laundering legislation; co-operation between revenue authorities; conventions for administrative assistance in tax administration | |
| Day 2 | Double taxation conventions and their application (focusing on OECD Model) |
| 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; causes of international double taxation; methods of relief from double taxation;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 | |
| Day 3 | Transfer pricing, thin capitalisation and BEPS |
| 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; BEPS provisions, including country-by-country reporting | |
| Day 4 | Case law and consideration of past ADIT exam questions |
| More extensive examination of case law relating to content of days 1-3 and applying knowledge to formulating responses to exam questions |
Pricing for 4-day course: £1950 plus VAT at 20%
Each day may be booked separately for £600 plus VAT per day
Cost includes tuition, full course documentation and refreshments including breakfast and lunch on each day.
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