Interpretation and Application of Tax Treaties

Amsterdam, 22-24 February 2010
Level: Introductory
Price: € 1,760 ($2,200) - Price for full IBFD Members: € 1,408
Course code: OC10IAT1
Download the course program

Overview and Learning Objectives

This course is designed to provide participants with a framework for understanding the main issues involved in the application of income tax treaties. In particular, the course will cover the residence issue, the concept of permanent establishment (PE), attribution of profits to a PE, passive income, employment income, double taxation relief, non-discrimination and triangular cases. The aim of the course is to make the participants aware of the wide range of tax issues that have to be addressed in applying tax treaties. The course will end each day with a case study to enable participants to gain confidence in applying the skills acquired during the course.
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.

Who Should Attend?

The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry and government officials. The course is particularly useful for tax professionals who have experience of their national tax system, but who have now moved to an international department who have encountered tax treaties on an occasional basis, but who wish to ensure that they are aware of the main problem areas of treaty law.

Course Level and Prerequisites

This is an introductory level course. Participants taking this course will be expected to have a good understanding of at least one national tax system, in particular:

- the domestic concept of residence
- the application of income tax to the foreign income of residents
- the domestic foreign tax relief
- the application of income tax to the domestic source income of non-residents

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

Introduction into Tax Treaties
Residence
The Permanent Establishment Concept
Business Profits
Passive Income
Employment Income
Double Tax Relief and Conflicts of Qualification
Non Descrimination and Triangular Cases
Case Studies

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: 19.5 (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 € 1,760 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