UnscheduledRecent Case Law on Tax Treaties

The course covers important international developments in tax treaties including recent OECD updates and case law, focussing in particular on case law since 2006. The focus of this course is on how these recent developments impact the application of double tax treaties with respect to corporate income taxation. It deals with relevant OECD updates and tax cases on the scope of treaty application and residence, treaty entitlement and the relationship between domestic anti-avoidance rules and tax treaties (including the beneficial ownerships concept), the concept of permanent establishments and PE profit attribution, the application of treaty non-discrimination principles and various treaty characterization problems.

 

This is an interactive course with a maximum of 30 participants. Prior to the course, participants will be given access to a documentation platform which provides them with additional pre-reading material and supplementary material (e.g. legal documentation, case law and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.

 

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

 

This is an advanced-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 and have experience in applying them.

In order to participate in this particular course, no advance preparation is necessary. However, 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: 20.5 (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.