09 - 12 Sep 2013Corporate Taxation: Tax Treaties and EU Aspects

This course provides a thorough understanding of the main issues involved in the application of income tax treaties and European Union (EU) tax law with respect to direct taxation of corporations. Specific emphasis will be put on the relevant provisions of the OECD and UN Model Conventions, the EU Treaty and the EU Directives. Recent developments in the application and interpretation of those provisions will be analysed in depth.
 
 
Type:
Open Course
Language:
English
Location:
Amsterdam - The Netherlands
Level:
Introductory
Course code:
OC13CTTEU1
Price:
€ 2,360 / $ 3,068 (VAT excl.)
VAT:
21% VAT is applicable on all courses attended in The Netherlands.
Client offer:
20% discount for IBFD Membership and Global Tax Explorer (Plus) clients.
 
Early Bird Discount: a 30% discount will be applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
 
Corporate Taxation: Tax Treaties and EU Aspects

Overview and learning objectives

This course is designed to give the participants a thorough understanding of the elements of international and EU tax law that are of practical importance with respect to the direct taxation of corporations. Course participants will gain an understanding of how to apply and use both tax treaties and EU tax law in their daily tax practice. The correlation between international and EU tax law and national tax systems will be examined and discussed as well. Specific emphasis will be put on the relevant provisions of the OECD Model Convention and the EU Treaty. Moreover, the course will cover the Parent-Subsidiary Directive and the Interest and Royalties Directive, which have a great impact on the tax planning of European companies. In addition, this course offers the opportunity to examine the leading cases of the Court of Justice of the European Union and the latest developments in the application and interpretation of tax treaties.
 
This is an interactive course, with case studies to enable participants to gain confidence in applying the skills acquired during the course. Prior to the course, participants will be given access to an online platform which provides them with additional pre-reading material and supplementary material (e.g. legal documentation, case law and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.
 
Field of study
Taxes

 

Who should attend?

The course is suitable for practitioners in tax advisory firms, in-house tax specialists in commerce and industry, tax authorities and government officials and judges dealing with tax cases. The course is particularly useful for tax professionals who have experience of their national tax system, but need to know about international and EU tax law and how it interacts with the national tax system.

 

Course level and prerequisites

This is an introductory-level course. Participants will be expected to have a basic knowledge of the tax system of at least one country in respect of corporate tax. 

 

Pre-course preparation

In order to participate in this particular course, no advance preparation is necessary. However, for some courses, suggested reading materials may be made available on our online platform a few weeks before the start of the course.
 

Interactive course - "Group Live" 

To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 30 participants will be accepted. Early registration is therefore recommended.


Continuing Professional Education

Recommended NASBA CPE points for this course: 25 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for ITA courses.
 

Course fee and registration details

The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.

  • Introduction to tax treaties and EU tax law
  • Residence
  • Permanent establishments (PE) concept
  • Taxation of business profits under tax treaties
  • EU fundamental freedoms and corporate taxation
  • Case law of the Court of Justice on corporate taxation: recent developments
  • Case law of the Court of Justice: tools in the toolbox
  • Double taxation and EU law: closing remarks
  • Treaty non-discrimination and triangular cases
  • Taxation of investment income under tax treaties
  • EU Interest and Royalties directive
  • Case studies
  • Bruno da Silva
    Bruno da Silva works at Loyens & Loeff, European Direct Tax Law team and he is a tax treaty adviser for the Macau special...
  • Timothy Lyons QC
      Timothy Lyons, QC, LLM, PhD, FTII, is a Barrister and a member of the Irish Bar and practises at Tax Chambers, Lincoln...
  • Giuseppe Melis
      Giuseppe Melis is Professor of Tax Law and of Tax Litigation at the Law Department of the University of Molise and at...
  • Belema Obuoforibo
    Belema Obuoforibo CTA, ATT is the Director of the IBFD Knowledge Centre as well as the IBFD in-house tax specialist for the...
  • Andreas Perdelwitz
    Andreas Perdelwitz is a Principal Research Associate in IBFD’s European Knowledge Group. Mr Perdelwitz obtained his law...
  • Rita Szudoczky
      Rita Szudoczky is a PhD candidate at the Amsterdam Centre of Tax Law of the University of Amsterdam and works at...