25 - 28 Jun 2012Practical Application of Tax Treaties

The course covers the application of the dual resident tie-breaker rules, the application and classification issues involving royalty payments and other passive income, the application of the Permanent Establishments (PE) concept and the attribution of PE profits, triangular cases, entity taxation and treaty anti-abuse rules.
 
Type:
Open Course
Language:
English
Location:
Amsterdam - The Netherlands
Level:
Intermediate
Course code:
OC12PATT1
Price:
€ 2,289 / $ 2,861 (VAT excl.)
IBFD Members:
Members receive a 20% discount
 
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).
 
Practical Application of Tax Treaties

Overview and Learning Objectives

The course covers the application of the dual resident tie-breaker rules, the application and classification issues involving royalty payments and other passive income, the application of the Permanent Establishments (PE) concept and the attribution of PE profits, triangular cases, entity taxation and treaty anti-abuse rules.


Who Should Attend?

The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry, and government officials.


Course Level and Prerequisites

This is an intermediate-level course. Participants taking this course will be expected to have a good understanding of at least one national tax system and the fundamentals of double tax treaties. The course will proceed on the assumption that participants already know the basic rules in tax treaties or have already attended the introductory course on Principles of International Taxation.
 

Pre-course Preparation

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.
 

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 CPE points for this course: 25.5 (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.
 

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.
  • Residence
  • Treaty Benefits and Anti-Avoidance Rules
  • Entity Taxation under Tax Treaty
  • Permanent Establishments
  • Attibution of Profits to Permanent Establishments
  • Passive Income
  • Taxation of Payments for Technology
  • Other OECD and UN Developments
  • Triangular Cases
  • 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...
  • Jan de Goede
    Jan de Goede is Senior Principal, Tax Knowledge Management, reporting to the CEO of IBFD. He previously held several...
  • Bart Kosters
    Bart Kosters is a Senior Principal Research Associate in IBFD’s Knowledge Centre. Until January 2010, he was in charge...