International Tax Academy
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CIOT's Advanced Diploma
 

   Tax Treaties Negotiations

Amsterdam, 9 - 12 February 2009
Level: Intermediate
Price: €  2,080 (US$ 2,600) - Price for full IBFD Members: € 1,664 (US$ 2,080)
Course code: OC09TTN1
Download the course program

This course is endorsed and supported by the Financing for Development Office of the United Nations Department of Economic and Social Affairs.
 UN
Overview and Learning Objectives  

This course is designed to give the participants a thorough understanding of all aspects of tax treaties negotiations and to enable them to identify priorities for their position during these negotiations. The first part of the course will deal with a discussion of the substantive issues in treaty negotiations on the basis of two diametrically opposed treaty texts. One text represents the desired outcomes of a developed country, whereas the other text represents those of a developing country. The differences between these texts will be discussed in detail, as well as the way in which appropriate compromises can be achieved.

The second part of the course will deal with the general principles of the negotiation process, how negotiators should prepare themselves, and the technical negotiation factors that determine this process. In addition, the Secretariat to the Committee of Experts on International Cooperation in Tax Matters of the United Nations will report on the recent developments in the discussions on the tax position of developing countries.


The third part of the course consists of a role play on the basis of the findings of the discussions which took place during the first two parts of the course. During the role play session, negotiations will be simulated and the participants will be trained on how to achieve an optimal result during negotiations.

This course is endorsed and supported by the Financing for Development Office of the United Nations Department of Economic and Social Affairs.


Who Should Attend?
The course is suitable for government officials who are involved in tax treaty negotiations, and
tax professionals from academia, tax advisory practice or industry, advising and/or assisting in tax treaty negotiations, or interested in the content and background of tax treaties.
Course Level and Prerequisites
This is an intermediate-level course. Participants taking part in this course will be expected to have a good understanding of at least one national tax system and the fundamentals of tax treaties. The course will be a highly interactive one, and participants will be expected to actively participate in the discussions and be ready to discuss issues of immediate relevance to their work and to share experiences for the benefit of the other participants.
Click here for more information about the course levels.
Advanced Preparation
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.
Topics Covered
  • Discussion of treaty texts - treaty scope and definitions
  • Discussion of treaty texts - business income
  • Discussion of treaty texts - passive income
  • Discussion of treaty texts - personal income
  • Discussion of treaty texts - other categories of income
  • Discussion of treaty texts - elimination of double taxation
  • Discussion of treaty texts - special provisions
  • The UN Model
  • The negotiation process
  • Simulation of tax treaty negotiations workshop
Instructors
(Click on the instructor's name to see the biography)
Interactive Course - "Group Live"
To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 30 participants will be accepted. Early registration is therefore recommended.
Continuing Professional Education
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.
General Course Information
Course Fee and Registration Details
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.
Registration
 
Contact
IBFD International Tax Academy
P.O. Box 20237
1000 HE Amsterdam
The Netherlands
Tel.: +31-20-554 0160
Fax: +31-20-620 9397
E-mail: itacourses@ibfd.org