• 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), is particularly relevant for Paper I of the ADIT diploma. It provides the participants with the fundamentals of international taxation. The course includes a substantial section on tax treaty interpretation and application, covering active and passive income, residence, double tax relief and the permanent establishment concept. Participants will be given the principles of transfer pricing, an overview of basic tax planning structures, and insight into the application of the most common anti-avoidance provisions.
• Interpretation and Application of Tax Treaties (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, the OECD transfer pricing methodologies and transfer pricing of intra-group services. Focus will be on OECD aspects of transfer pricing and examples will be used throughout the course. 
• Principles of Transfer Pricing (4-day course), introduces participants to transfer pricing principles and methodologies and the application of these principles and methodologies to specific categories of intra-group dealing (including; intra-group services, intangibles and intra-group finance). The focus of this practically oriented course is on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the issues that can arise in the application of these requirements.

FURTHER INFORMATION
More information on the content of the courses, course scheduling (ITA Course Calendar) and course fees can be found on the IBFD web site, or contact itacourses@ibfd.org for further information.

All the courses mentioned below can be taken as follow-on to:

• Summer Course;
• Principles of International Taxation;
• Interpretation and Application of Tax treaties (for tax-treaty related topics); or
• Principles of Transfer Pricing (for transfer pricing-related topics);
• Introduction to Transfer Pricing (for transfer pricing-related topics).

or would be suitable for participants who are already comfortable with the basic allocation rules of treaties and wish to deepen their understanding.

• Practical Application of Tax Treaties (4-day course), offers participants more thorough analyses of the complex issues raised by the application of tax treaties. The course covers the application of the dual-resident tie-breaker rules, classification issues involving royalty payments and other passive income, the application of the permanent establishment concept and the attribution of permanent establishment profits, triangular cases, employment income, entity taxation and treaty anti-abuse rules.
• Tax Treaties Workshop (2-day course), offers an in-depth insight into the concept of permanent establishments and the attribution of profits to these permanent establishments in tax treaties and the application of tax treaties to triangular cases. 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.
• Treaties and Tax Planning (2-day course), offers in-depth understanding of how treaties are used in practice for tax planning purposes. The topics covered include the use of hybrid entities and hybrid instruments for tax planning purposes and the relevant treaty rules that may help or hinder these techniques, including the application of anti-abuse rules in tax treaties.
• International Tax Aspects of Permanent Establishment (4-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.
• 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.

• 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 (M&A). In considering the tax effects of cross-border M&A transactions, an analysis will be made of the various tax rules that come into play.
• Tax Aspects of Fund Structuring and Acquisition Techniques (2½-day course), provides participants with an in-depth analysis of the legal and tax issues related to private equity and venture capital.
• International Tax Planning for Multinational Enterprises (2-day course), provides participants with a practical understanding of international tax planning tools for multinational enterprises, with particular reference to tax planning techniques and trends for holding, financing, manufacturing, R&D and selling activities.
• Practical Aspects of International Tax Planning (5-day course), provides participants with an overview of basic corporate financing options. In addition, the use of innovative financial instruments such as hybrids and derivatives for corporate financing purposes will be addressed. The course will also cover tax planning techniques and trends for manufacturing, R&D and selling activities of multinational enterprises.
• Transfer Pricing: Intangibles and Intra-group Finance (3-day course), explores the application of transfer pricing principles to intangible property and to intra-group financing arrangements.
• Transfer Pricing Aspects of Business Restructurings (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 Workshop (2-day course), is an advanced-level workshop comprising a rolling case study that explores the transfer pricing issues relating to the distribution, manufacturing, R&D, financing and management operations of a multinational group.

Please note that none of the above courses is of itself sufficient preparation for Paper I of the CIOT exam.

FURTHER INFORMATION
More information on the content of the courses, course scheduling (ITA Course Calendar) and course fees can be found on the IBFD web site, or contact itacourses@ibfd.org for further information.

• EU Direct Corporate Taxation (4-day course), provides a thorough understanding of EU tax law with respect to the direct taxation of corporations. The provisions of the EC Treaty, the Parent-Subsidiary Directive, the Merger Directive and the Interest and Royalties Directive will be examined. The landmark cases of the European Court of Justice (ECJ) and the recent developments will be also covered.
• Corporate Taxation - International and EU Aspects (3-day course), provides participants with a thorough understanding of the practical and conceptual elements of EU law with respect to direct corporate taxation. Specific emphasis will be put on the provisions of the EC Treaty and Directives, the leading cases of the European Court of Justice (ECJ) and the latest EU developments.
  
• Introduction to European Value Added Tax (4-day course), provides participants with a framework of the most important VAT principles and issues which anyone dealing with VAT in the European Union is confronted with and needs to understand.
  

• European Value Added Tax - Selected Issues (2-day course), focuses on complex issues that can arise for international businesses in the application of VAT in the European Union. The course will cover intra-Community (triangular) supplies of goods and services, consignment stock and warehousing arrangements and VAT planning and control
• 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.

More information on the content of the courses and the course calendar can be found on the

IBFD International Tax Academy web site.

DOCUMENTATION AND RESOURCES FOR ITA OPEN COURSES

• Documentation Binder: Participants on all ITA open 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.
• Online Platform: 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.
• Selected IBFD Database(s): Participants also have access for 2 weeks after the course to (a) relevant IBFD database(s).
• IBFD Library Access: Participants also have access to the extensive IBFD library for their own research. To ensure that a place is available for you, please contact the library directly via email.

FURTHER INFORMATION