UnscheduledInterpretation and Application of Tax Treaties

This course is designed to provide participants with a framework for understanding the main issues involved in the application of income tax treaties. In particular, the course will cover the residence issue, the concept of permanent establishment (PE), attribution of profits to a PE, passive income, employment income, double taxation relief, non-discrimination and triangular cases. The aim of the course is to make the participants aware of the wide range of tax issues that have to be addressed in applying tax treaties. The course will end each day with a case study to enable participants to gain confidence in applying the skills acquired during the course.

 

The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry and government officials. The course is particularly useful for tax professionals who have experience of their national tax system, but have now moved to an international department and those who have encountered tax treaties on an occasional basis, but wish to ensure that they are aware of the main problem areas of treaty law.

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 the taxation of foreign income derived by resident individuals and domestic-source income received by non-resident individuals. Participants will be expected to know the definition of "residence" in their own country, to know how their country gives relief for foreign tax and to know when non-resident individuals are taxable. A very basic understanding of the function of double tax treaties would be helpful, but the course will proceed on the basis that course participants are new to dealing with treaties. 
 

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

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.

Recommended CPE points for this course: 19.5 (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.
 

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.