UnscheduledRecent Developments in International Taxation: US, EU and Tax Treaty Aspects
- Recent Developments in International Taxation: US, EU and Tax Treaty Aspects
Overview and Learning Objectives
The course covers the current developments in international taxation, with a specific focus on US, EU and tax treaty aspects of corporate taxation. The topics covered include treaty corporate residence, recent OECD and UN developments on the permanent establishment (PE) concept and attribution of profits to PEs, treaty entitlement of investment vehicles and concept of beneficial owner. Other recent OECD and UN treaty developments are also discussed, including changes to the Model Tax Conventions and/or Commentaries on Articles 12 (royalties), 13 (capital gains), 15 (income from employment), 17 (artistes and sportsmen) and 24 (non-discrimination) and the addition of an arbitration provision to the Mutual Agreement Procedure (MAP) under Article 25 of the Model Conventions. Then the course deals with the latest developments in US international taxation, transfer pricing, tax treaty practice and current related issues on business restructuring. Finally, the course provides an update on EU corporate taxation, with a specific focus on the Common Consolidated Corporate Tax Base (CCCTB), and the recent case law of the EU Court of Justice.
This is an interactive course with a maximum of 30 participants. Participants will have a chance to discuss their questions with renowned experts in international taxation. 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.
Field of study
TaxesWho should attend?
The course is suitable for practitioners in tax advisory firms, in-house tax specialists in commerce and industry, tax authorities 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 the fundamentals of international tax law and tax treaties and be familiar with the issues that may arise from their application.
In order to participate in this particular course, no advanced 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 NASBA 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.
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.
- Treaty Corporate Residence
- (Re)shaping the Boundaries of the Permanent Establishment (PE) Concept
- Treaty Rules for Taxing Business Profits
- Concept of Beneficial Owner
- Investment Vehicles and Treaty Entitlement
- Other OECD and UN Treaty Developments
- US International Taxation and Recent Developments
- US Transfer Pricing and Tax Treaty Practice: Latest Developments
- Common Consolidated Corporate Tax Base (CCCTB) in the EU
- Other Topical Developments in EU Tax Law
- EU Case Law and Recent Developments
- David L. Cameron
- David L. Cameron is Associate Director of the Tax Program and Senior Lecturer at Northwestern University School of Law...
- Jan de Goede
- Jan de Goede is Senior Principal, Tax Knowledge Management reporting to the CEO of IBFD. He previously held several...
- Ioanna Mitroyanni
- Ioanna Mitroyanni is a tax lawyer and works as a policy officer at the European Commission, Directorate General for Taxation...
- Carsten Zatschler
- Carsten Zatschler is the Head of Cabinet of Sir Konrad Schiemann, the British judge at the Court of Justice of the...