UnscheduledTax Treaties Negotiations Workshop
Giving you the confidence to successfully negotiate tax treaties is the principal objective of this course. The course commences with a broad explanation of the role of tax treaties in the international legal order and their relationship with domestic law. We will discuss various provisions that can be included in tax treaties based on the OECD and UN Models and the implications of these on the scope and application of tax treaties, the distributive rules for different categories of income, elimination of double taxation and special administrative rules.
Please note: This course is not currently scheduled. The price, program and instructors are detailed as per the previous course for information purposes only and may be subject to change.
- Type:
- Open Course
- Language:
- English
- Location:
- Amsterdam - The Netherlands
- Level:
- Intermediate
- Course code:
- OC12TTN1
- Price:
- € 1,700 / $ 2,125 (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).
- Tax Treaties Negotiations Workshop
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Overview and Learning Objectives
This course is designed to give the participants a thorough understanding of all aspects of tax treaties negotiations and to enable them to identify priorities for their position during these negotiations. The first part of the course will deal with a discussion of the substantive issues in treaty negotiations on the basis of two diametrically opposed treaty texts. One text represents the desired outcomes of a developed country, whereas the other text represents those of a developing country. The differences between these texts will be discussed in detail, as well as the way in which appropriate compromises can be achieved.
The second part of the course will deal with the general principles of the negotiation process, how negotiators should prepare themselves, and the technical negotiation factors that determine this process.The third part of the course consists of a role play on the basis of the findings of the discussions which took place during the first two parts of the course. During the role play session, negotiations will be simulated and the participants will be trained on how to achieve an optimal result during negotiations.Who Should Attend?
The course is suitable for government officials who are involved in tax treaty negotiations, and
tax professionals from academia, tax advisory practice or industry, advising and/or assisting in tax treaty negotiations, or interested in the content and background of tax treaties.Course Level and Prerequisites
This is an intermediate-level course. Participants taking part in this course will be expected to have a good understanding of at least one national tax system and the fundamentals of tax treaties. The course will be a highly interactive one, and participants will be expected to actively participate in the discussions and be ready to discuss issues of immediate relevance to their work and to share experiences for the benefit of the other participants.
Pre-course Preparation
In order to participate in this particular course, no advance preparation is necessary. However, for some courses, suggested reading materials may be made available on our online 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 EducationRecommended CPE points for this course: 25 (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.
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- Introduction to Tax Treaties
- Discussion of the Tax Treaties - Treaty Scope and Definitions
- Discussion of the Tax Treaties - Business Income
- Discussion of the Tax Treaties - Passive Income
- Discussion of the Tax Treaties - Personal Income
- Discussion of the Tax Treaties - Other Treaty Articles - Other Cathegory of Income
- Discussion of the Tax Treaties - Other Treaty Articles - Elimination of Double Taxation
- Discussion of the Tax Treaties - Other Treaty Articles - Special Provisions
- The UN Model
- The Negotiatiion Process
- Simulation of Tax Treaties Negotiations Workshop
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- Jan de Goede
- Jan de Goede is Senior Principal, Tax Knowledge Management, reporting to the CEO of IBFD. He previously held several...
- Ridha Hamzaoui

- Ridha Hamzaoui is Manager of the Africa-Middle East Knowledge Group for IBFD. Before joining IBFD, he worked as a senior tax...
- Bart Kosters

- Bart Kosters is a Senior Principal Research Associate in IBFD’s Knowledge Centre. Until January 2010, he was in charge...
- Wim Wijnen
- Wim Wijnen is Counsel to the Academic Chair of IBFD. He is also a teacher of International Tax Law at Libera Universit...