IBFD - CIOT’s Advanced Diploma in International Taxation

CIOT’s Advanced Diploma in International Taxation

The International Tax Academy (ITA) is IBFD's training centre, founded in 1989. It offers a wide range of international tax courses and organizes conferences and seminars on specialized topics. Our courses are held in Amsterdam (the Netherlands), in Kuala Lumpur (Malaysia), in Hong Kong (China) and in Singapore.

A number of ITA courses provide a good grounding for several topics of the Advanced Diploma in International Taxation.

PAPER I

Summer Course (2-week course), provides a thorough grounding in the basic principles, gives an awareness of all the major issues that students of international tax law will encounter in the field of income taxation and introduces the participants to the vital art of treaty interpretation. A large part of the course is about double tax treaties, but the course also deals with the wider context in order to put treaty law in perspective.
Principles of International Taxation (5-day course), provides the participants with fundamentals of international taxation. The course includes a substantial section on tax treaty interpretation and application, covering both active and passive income. Participants will be provided with the principles of transfer pricing, an overview of basic tax planning structures, and gain insight into the application of the most common anti-avoidance provisions.
Interpretation and Application of Tax Treaties I (3-day course), focuses on treaties and provides a compact introduction to the most important allocation rules. Given the much shorter time frame, however, it does not provide the same breadth as the Summer Course or the Principles of International Taxation course.
International Taxation of Expatriates (3-day course), also functions as an introduction to treaties, but with a specific focus on the taxation of individuals, tax implications of cross-border employment activities, pensions and stock options.
Introduction to Transfer Pricing (2-day course), provides an introduction to the most important principles of transfer pricing for tax purposes. Focus will be on OECD aspects of transfer pricing and examples will be used throughout the course.
Principles of Transfer Pricing (3-day course), covers the various approaches to the determination of profits of branches and associated enterprises, Article 9, Advance Pricing Agreements and the OECD Transfer Pricing Guidelines.
Transfer Pricing of Intangibles (2-day course), provides a good understanding of the many complicated issues regarding intangibles in transfer pricing, both from an OECD and a US perspective.
Transfer Pricing and Business Restructuring (3-day course), highlights, from an academic and practical standpoint, the main tax issues arising when business restructuring takes place, so as to provide participants with a thorough knowledge of the most relevant transfer pricing issues to be taken into account when a business restructuring takes place within an MNE.
Transfer Pricing - Selected Issues (2-day course), provides participants with an in-depth coverage of the critical areas of transfer pricing currently subject of developments in the international tax arena and discussion amongst scholars and the tax community.

All the courses mentioned below can be taken as follow-on to either the Summer Course or Treaties I, or would be suitable for participants who are already comfortable with the basic allocation rules of treaties and wish to deepen their understanding. Participants on these courses are expected to be familiar with the basic allocation rules and be able to discuss the arguments for and against a particular interpretation of a treaty.

Interpretation and Application of Tax Treaties II (2-day course), explores some of the more complex issues raised by tax treaties, such as entity classification, triangular cases, and anti-avoidance provisions, for which there are not always clear solutions.
Tax Treaties Workshop (2-day course), offers an in-depth insight into the interpretation of tax treaties, the separate entity approach of permanent establishments, and also explores the mutual agreement procedure. It is conducted as a series of case studies and role play sessions, with the workshop leaders taking time to explain and discuss relevant issues as they arise.
Avoidance of Double Taxation (2-day course), explores in detail the complications of the two basic relief methods.
International Tax Aspects of Permanent Establishments (3-day course), explores the concept of permanent establishment in depth. Practical issues, such as VAT and profit allocation will be covered. This will be combined with the use of case studies to ensure that participants leave the course with the confidence to apply what they have learned.
Permanent Establishment Workshop (2-day course), is an advanced level, interactive workshop consisting mainly of case studies and is designed for participants that are familiar with the basic issues relating to the permanent establishment concept and the attribution of profits.
Corporate Financing (2-day course), offers both depth and breadth in respect of the direct and indirect tax issues arising from the implementation of various corporate financing methods.
Hybrid Financial Instruments (2-day course), covers tax issues arising from the issuance of hybrid financial instruments as a tool for the implementation of various cross-border corporate financing techniques, with particular emphasis on their increasing use in the light of the implementation of the Basel Capital Accord and the IAS/IFRS principles.
Derivative Instruments (2-day course), deals with the legal, accounting and tax aspects of derivative instruments. Particular attention is given to the tax treatment of such instruments from a domestic and international tax perspective.
International Taxation of Trusts (3-day course), deals with international tax law on a regular basis and who need to understand the specific taxation issues raised by private and family trusts; its aim is to give the participants a framework within which to approach trusts and their taxation.
Mergers and Acquisitions (2 ½ -day course), provides participants with an in-depth analysis of the tax consequences arising from cross-border mergers and acquisitions transactions.

PAPER II

Introduction to US Transfer Pricing (3-day course), provides an introduction to the most important principles of transfer pricing for tax purposes as implemented by the US Internal Revenue Service.
US Corporate Taxation (3-day course), is intended to give participants an overview and a good understanding of the US system and its terms and concepts, with particular emphasis on international aspects. Focus will be on corporate taxation.

PAPER III

EU Corporate Direct Taxation (4-day course), gives a good introduction to the many ways in which the European Union impacts on corporate direct taxation. A whole day is devoted to the case law of the European Court of Justice.
European Value Added Tax (4-day course), focuses on selected issues of value added tax in the European Union, e.g. the VAT treatment of e-commerce, intra-Community services and transactions as well as triangular transactions and the use of consignment stock and warehouses. Taking into account the applicable directives, regulations and relevant and most recent case law of the European Court of Justice, these issues will be explored practically and in detail.
Introduction to European Customs Law and Excise Duty (3-day course), designed to give participants a framework for understanding the main issues involved in the application of customs law within the European Union.
US Corporate Tax (3-day course), similarly gives a good introduction to the complexities of US corporate taxation.
Taxation of Holding Companies in Europe (2-day course), deals with the tax aspects to be taken into account when dealing with holding companies in Europe. The course addresses the technicalities of the widely used EC Corporate Direct Tax Directives and the use of holding companies also for financing and IP management activities. The course contains a session on the tax aspects that should be taken into consideration by a US-based group setting up its holding company in Europe.

Neither course, however, is of itself sufficient preparation for Paper III of the CIOT exam.

More information on the content of the courses and the course calendar can be found on the IBFD web site.

Participants on all ITA courses are provided with a documentation binder containing a selection of articles on the course topics for future reference after the completion of the course in question. Participants also have access for 6 weeks after the course to an online platform which provides additional learning resources (e.g. legal documentation, case law and related articles/literature), allowing participants to expand their knowledge after the course, and to a relevant IBFD database for 2 weeks after the course.
Participants also have access to the extensive IBFD library for their own research. To ensure that a place is available for you, contact the library directly via email.

CIOT have negotiated a discount of 20% (no other discount or reduction to the course fee will apply) on all ITA open courses. In order to receive a discount you must quote your CIOT membership number or ADIT number at the time of registration. Contact itacourses@ibfd.org if you need further information.

Discount for CIOT members

CIOT members receive 20% discount on all ITA open courses (no other discount or reduction to the course fee will apply). Just quote your CIOT membership number or ADIT number at your registration. Contact ITA for further information.

For further information on in-house courses contact:
Arcotia Hatsidimitris
Head ITA
P.O. Box 20237
1000 HE Amsterdam
The Netherlands
Tel.: +31-20-554 0180
E-mail: Arcotia Hatsidimitris

General course enquiries:
Tel.: +31-20-554 0160
Fax: +31-20-620 9397
E-mail: ITA