Tax Treaties
About This Course
At the end of the course, participants will :
1. Gain a comprehensive understanding of key concepts in international tax law, including the reasons for cross-border taxation and the challenges of double taxation. Analyze the methods used to relieve juridical double taxation and explore the types of relief countries may offer regarding economic double taxation.
2. Develop a solid foundation in tax treaties and treaty residence, including an examination of the interaction between distributive articles and double taxation relief provisions. Understand the key concepts of residence and source, with a focus on in-depth analysis of residence.
3. Explore and analyze the distributive rules of OECD Model Article 7, which governs business profits. Understand the main rule and the exception for business conducted through a permanent establishment (PE) in another state. Examine the concept of PE in detail, including physical PE, project PE, Agency PE, and other non-OECD types of PE.
4. Examine the taxation of dividends, interest, and royalties under Articles 10, 11, and 12 of the tax treaties. Understand the flat-rate gross-basis taxation in the source country and the subsequent taxation in the residence country. Analyze theoretical and practical issues related to investment income taxation.
What You'll Learn
This course deals with tax treaties: (bilateral) agreements among states which provide the rules that eliminate double taxation when a resident of one country derives income from the other country. Such income may be income from business operations in the other country (e.g., trading, rendering services, manufacturing), from foreign employment or in the form of dividends, interest and royalties. In addition, tax treaties aim at countering international tax avoidance that may result from mismatches between the domestic taxing rules of the two treaty states and, through administrative assistance, tax evasion through nonreporting and (other) fraud.
Entry Requirements
A good Bachelor's or Juris Doctor degree in Law