OnlineITA105 Passive Income

• Understand the basic treaty distributive rules for income from immovable property, dividends, interest, royalties and capital gains and when these rules are applicable
• Awareness of the various tax treaty rules that may be applicable to technical services fees
• Appreciate the similarities and differences in the tax treaty treatment of various types of passive income
• Ability to apply the distributive rules to payments of passive income, including when they are derived by permanent establishments and when the payments are under non-arm's length terms
• Awareness and understanding of the areas of potential difficulty in connection with the application of the tax treaty rules for passive income

This course introduces the tax treaty rules that may be applicable to cross border passive income such as income from immovable property, dividends, interest, royalties, capital gains and technical services fees. Participants should be familiar with the basic principles of tax treaties in addition to the domestic law of at least one country, in particular as it relates to the taxation of cross-border income. Participants, particularly those with limited knowledge of tax treaties, are recommended to first complete the course ITA101 "Fundamentals of Tax Treaties”.

• Audio lessons: 4.5 hours
• Self study: 7 hours
• Further reading (optional): 15 hours
• Extra: 25 min video interview with international tax expert

Access to the course is granted for a period of 8 weeks.

Continuing Professional Education (CPE)

The recommended CPE points for this course are as follows:

CIOT (The UK Chartered Institute of Taxation) – 12 points

In addition, ITA Online courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect.

Read more information on CPE points and accreditation for ITA courses.