ITA Integrated

Many benefits can be realized by combining these different methods of training:

 

• Foundation concepts can be studied online at the participants’ own pace.
• Having completed the online course, participants enter the classroom with the same level of understanding of key concepts ensuring maximum benefit from the live training.
• Classroom sessions can focus on reinforcing and building on key concepts, exploring practical application and more complex issues.

Online and open courses

ITA offers integrated online training with selected open or in-house courses. Participants who register for one of these “integrated” courses, will have access to complete an online module before attending the open course sessions. For these courses the cost of the online module is included in the course fee.

Fundamentals of tax treaties (approximately 8 weeks self-study):

 

• How tax treaties operate
• How treaties interact with domestic law
• Interpretation and practical application of tax treaties
• Eligibility to treaty benefits
• The role of model treaties and commentaries

Open course training

Application of international tax treaties (2-days classroom training):

 

• Residence
• Permanent establishments
• Employment income
• Business profits
• Passive income
• Case studies

Online and in-house training

In-house training can also be combined with online courses. In consultation with the client, ITA can design an integrated training program best suited to the level and knowledge requirements of participants.

Example 2: Permanent Establishments
Level: Intermediate/advanced

 

Permanent establishments (approximately 8 weeks self-study):

 

• The importance of the PE concept
• The PE concept under domestic law v. tax treaties
• When cross-border business activities constitute a PE
• Types of PEs
• The consequences of finding a PE

Permanent Establishments Workshop (2-days classroom training):

• Case study – Identification of PE risks in a multinational corporate structure
• Role play session – Agency PE
• Case study – Profit attribution and characterization of dealings
• Triangular cases