This course is designed to provide participants who deal with double tax treaties on a regular basis an in-depth understanding of some of the more complex issues raised by double tax treaties and how they are used in practice for tax planning purposes. The course includes complex cases studies on permanent establishments, triangular cases, partnerships, anti-avoidance rules and their application for tax planning purposes. The course also provides insight on the tax treaty aspects of hybrid entities and hybrid instruments.

Prior to the course, participants will be given access to an online 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.

The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry, and government officials.

This is an advanced-level course. Participants taking this course will be expected to have a good understanding of at least one national tax system and the fundamentals of double tax treaties.
Click here for more information about the course levels.

In order to participate in this particular course, no advanced preparation is necessary. However, for some courses, suggested reading materials may be made available on our online platform a few weeks before the start of the course.

• Permanent Establishment and Business Profits
• Role Play Session - Agency PE
• Role Play Session - Characterization of Dealings between Head Office and Permanent Establishments
• Triangular Cases (with complex case study)
• The Application of Tax Treaties to Partnerships
• Tax Structuring through Hybrid Entities
• Tax Treaty and Hybrid Instruments
• Treaty Shopping, Limitation on Treaty Benefits and Anti-Avoidance Measures
• Case Studies

(Click on the instructor's name to see the biography)

• Joel Cooper
• Shee Boon Law
• Jan de Goede
• Belema Obuoforibo
• Marcel Buur
• Tigran Mkrtchyan

Recommended CPE points for this course: 26 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Click here for more information on CPE points and accreditation for ITA courses.

• Course Venue
• Accommodation and Travel
• About the International Tax Academy
• Terms and Conditions and Cancellation Policy
• General Course Information

The course fee of € 2,080 covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered.
Click here for our payment details, terms and conditions and cancellation policy.