This is an introductory level course designed to give the participants a framework for understanding the main issues involved in the application of income tax treaties, suitable for those who work in a tax advisory practice, in industry or in government. The course would be particularly useful for tax professionals who have experience of their national tax system, but who have now moved to an international department where they have to deal with treaties. It would also be useful for participants who have encountered treaties on an occasional basis, but who wish to ensure that they are aware of the main problem areas of treaty law.

Topics covered in this course:

The Permanent Establishment (PE) Concept

• The role of the permanent establishment concept in treaties
• Equivalent national concepts
• E-commerce

Residence

• The concept of residence
• Dual residence issues
• US savings clause

Business Profits

• Allocation of taxing rights over business profits
• Basic transfer pricing issues

Passive Income

• Taxing rights over dividends, interest, royalties and capital gains
• Scope of the provisions
• Beneficial ownership requirement
• Attribution of taxing rights
• What is a withholding tax?

Employment Income

•    Taxation of dependent personal services
•    General rules (183-day rule)
•    Hiring-out of labour
•    Frontier workers
•   Taxation of special payments and pensions
•   Taxation of directors, artistes and sportsmen
•    Implications for the employing company