Objectives:
 
Obtain an overview of the international tax environment
Be aware of aspects of domestic tax systems with a cross-border impact
Understand how tax treaties operate and the most important provisions
Be aware of the main methods of double taxation relief and how to apply them
Understand the role of model tax treaties and their commentaries
Ability to determine when treaty benefits are available (eligibility)
Appreciate the tax treaty making process and some of the broader policy issues that impact
the development of international tax policy
Be aware of the issues arising from, and principles of, tax treaty interpretation

Course includes:
 
Audio lessons: 3.5 hours
Self study: 12 hours
Further reading: 7 hours
Extra: 1 hour of video interviews with UN and other international tax experts
 
When courses are available with Chinese audio other components eg. self study, quizzes, further reading etc. remain in English.
 
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Objectives:
 
Understand the importance of the residence concept as a connecting factor between a taxpayer
and a national tax system
Appreciate the variety of ways in which countries define the residence connection for individuals
and companies
Understand the concept of dual residence and possible consequences of being a dual resident
Learn how to determine residence for treaty purposes and apply the remaining treaty articles
Become aware of more complex issues related to residence

Course includes:
 
Audio Lessons: 2 hours
Self study: 6 hours
Further reading: 16 hours
Extra: Video interview with leading tax expert, Prof. Hugh Ault
 
When courses are available with Chinese audio other components eg. self study, quizzes, further reading etc. remain in English.
 
Download Syllabus | Download Syllabus in Chinese

Objectives:
 
Understand the importance of the PE concept in the attribution of taxation rights on profits
derived from cross-border business activities
Appreciate the variety of ways in which states define equivalent concepts in their domestic law
Understand the various types of PE dealt with in both the OECD and the UN Model
Ability to determine whether cross-border business activities of an enterprise constitute a PE
Awareness of the consequences of finding a PE in a state

Audio Lessons: 4 hours
Self study: 16 hours
Further reading: 34 hours
Extra: Video interview with international tax practitioner, Patrick Ellingsworth
 
When courses are available with Chinese audio other components eg. self study, quizzes, further reading etc. remain in English.

Download Syllabus | Download Syllabus in Chinese

Objectives:
 
Understand the basic treaty distributive rules for income from immovable property, dividends,
interest, royalties and capital gains and when these rules are applicable
Awareness of the various tax treaty rules that may be applicable to technical services fees
Appreciate the similarities and differences in the tax treaty treatment of various types of
passive income
Ability to apply the distributive rules to payments of passive income, including when they are
derived by permanent establishments and when the payments are under non-arm's length terms
Awareness and understanding of the areas of potential difficulty in connection with the application
of the tax treaty rules for passive income

Audio Lessons: 4.5 hours
Self study: 7 hours
Further reading: 15 hours
Extra: 25 min video interview with international tax expert
 
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Objectives:
 
Understand the importance of business profits articles in tax treaties to the attribution of taxation
rights on cross-border business activities
Understand the differences between the business profits articles in the OECD and the UN Models
Appreciate the various approaches states may take in attributing profits to permanent
establishments
Awareness and understanding of the areas of potential difficulty in connection with the treatment
of internal dealings between PEs and other parts of the enterprise
Awareness of recent developments with respect to the attribution of profits to PEs

Course includes:
 
Audio lessons: 3 hours 15 mins
Self study: 14 hours 45 mins
Further reading: 29 hours
Extra: 40 min video interview with international tax expert, Philip Baker QC

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