OnlineITA106 Business Profits

Acquire a comprehensive understanding of the tax treaty rules applicable to business profits. Learn about the various approaches states may take in attributing profits to permanent establishments (PEs) and the main differences between the business profits articles in the OECD and the UN Models. Be aware of the recent developments with respect to the attribution of profits to PEs.
 
Type:
Online Course
Language:
English
Price:
€ 499 / $ 674 (VAT excl.)
IBFD Members:
Members receive a 20% discount
 
Ordering multiple courses: to order more than one online course please view our instructions.

 

ITA106 Business Profits

Learning objectives

After completing this course you will be able to:

 

  • Recognize the importance of business profits articles in tax treaties to the attribution of taxation rights on cross-border business activities
  • Identify the differences between the business profits articles in the OECD and the UN Models
  • Fully grasp the various approaches states may take in attributing profits to permanent establishments
  • Identify the areas of potential difficulty in connection with the treatment of internal dealings between PEs and other parts of the enterprise
  • Distinguish recent developments with respect to the attribution of profits to PEs

Level

Introductory

 

Pre-requisites

This course introduces the tax treaty rules applicable to business profits. 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, and should be familiar with the permanent establishment concept. Participants, particularly those with limited knowledge of tax treaties, are recommended to first complete the course ITA101 "Fundamentals of Tax Treaties” and ITA103 “Permanent Establishments”.
 

Study time

 

  • Audio lessons: 3 hrs 15 mins
  • Self study: 4 hrs 
  • Further reading (optional): 39 hrs
  • Extra: 40 min video interview with international tax expert, Philip Baker QC

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) – 8 points
  • NASBA (The National Association of State Boards of Accountancy, US) – 7 points

The IBFD ITA is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State board of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417. Web site: www.nasba.org.

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.

For more information regarding administrative policies such as complain and refund, please contact the International Tax Academy via email. Please note that once access to an online course has been granted, a refund will no longer be possible.

Order this course now by selecting 'Register Online' above.

  • Introduction to business profits
  • OECD and UN Models – Overview of Art. 7
  • Approaches to profit allocation
  • Attribution of revenues and expenses
  • Internal dealings
  • Introduction to advanced topics

Authors:

 
  • Bart Kosters
    Bart Kosters is a Senior Principal Research Associate in IBFD’s Knowledge Centre. Until January 2010, he was in charge...
  • Harry Tonino
    Harry Tonino is Principal Research Associate at IBFD’s International Tax Academy, where he specializes in corporate...
 

Other Contributors:

 
  • Philip Baker
    Philip Baker is a Queen’s Counsel practising from Grays Inn Tax Chambers in London. He specialises in international tax...
  • Joel Cooper
    Joel Lachlan Cooper is an international tax professional (specializing in transfer pricing) with a multidisciplinary education...
  • Jan de Goede
    Jan de Goede is Senior Principal, Tax Knowledge Management, reporting to the CEO of IBFD. He previously held several...
  • Joanna Wheeler
    Joanna Wheeler, TEP, is a member of the IBFD academic group. Previously, she was the editor of many different IBFD...