AMSTERDAM - [February 22, 2010 - February 24, 2010]
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.
AMSTERDAM - [February 25, 2010 - February 26, 2010]
Transfer pricing is one of the most important international tax issues faced by multinational enterprises and tax administrations today. This 2-day course introduces participants to the fundamental principles of transfer pricing, the transfer pricing methodologies, and the application of thereof. The course focuses on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and the delivery of the formal sessions complemented by interactive case studies and practical examples.
This course is designed to provide participants with an in-depth analysis of the tax consequences arising from cross-border mergers and acquisitions (M&A) transactions. The course covers the full scope of M&A focusing on various techniques that should be in place in order to successfully take over a business. In particular, in considering the tax effects of cross-border M&A transactions, an analysis of the various tax rules that come into play will be made including: (i) the foreign rules of a domestic tax law system, i.e. inbound and outbound transactions; (ii) applicable provisions of double tax treaties and (iii) the interaction of domestic tax law provisions and tax treaties at the supranational level (e.g. the European Union).
There are many reasons why a multinational enterprise may restructure its operations, but regardless of the underlying reasons, the international tax consequences, and particularly the transfer pricing aspects, require thoughtful consideration. This 3-day course is aimed at providing participants with a thorough knowledge of the transfer pricing issues relating to business restructures. The course covers business restructuring trends and the application of the relevant international tax and transfer pricing principles, along with a practical insight as to how a multinational might approach a restructure. In addition, the German tax law dealing with the transfer of functions transfers is explored in depth. The delivery of the formal sessions is complemented by an interactive case study.
This course provides participants with an overview and a good understanding of the complex Indian tax system, with particular emphasis on international aspects. The main focus of the course is on corporate taxation.
This course is designed to provide participants with the essentials of international taxation. The first three days are dedicated to the fundamental concepts relevant to the interpretation and application of international tax treaties. This introduction provides participants with the conceptual tools to fully grasp issues discussed on Day 4 and Day 5. Day 4 deals with the principles of transfer pricing and how these principles apply to intra-group services. Day 5 provides an overview of basic tax planning structures and an insight into the application of the most common anti-avoidance provisions.
This course provides participants with an in-depth analysis of the legal and tax issues related to Debt and Financial Restructuring in the context of current financial crisis. More specifically, it describes the legal and tax aspects that have to be taken into account in making the restructuring decisions and it gives a detailed overview of the structures and techniques used in daily practice.
It is often said that transfer pricing is not an exact science, hence to develop an understanding of transfer pricing principles and methodologies, consideration of their practical application is considered paramount. This 4-day course introduces participants to transfer pricing principles and methodologies and the application of these principles and methodologies to specific categories of intra-group dealing. These sessions are complemented by practical sessions that cover the application of the principles and methodologies in practice. The focus of this practically orientated course is on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the issues that can arise in the application of these requirements.
This intermediate-level course is aimed at analysing the fundamentals of international tax planning in a structured and consistent manner, deepening the knowledge of tax planning techniques of the participants. Although the course will focus on practical cases, domestic legislation will not be addressed in specific detail.
This course is designed to provide participants with a framework of the most important VAT principles and issues which anyone dealing with value added tax in the European Union is confronted with and needs to understand. The course will end each day with a case study to enable participants to gain confidence in applying the skills acquired during the course. This is an interactive course with a maximum of 30 participants. 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 on corporate financing relevant to the course.
This course is designed to provide participants with an in-depth analysis of the concept of permanent establishment (PE). Practical issues, such as allocation of profits and VAT aspects of PEs, will be covered. This will be combined with the use of case studies to ensure that participants leave the course with the confidence to apply what they have learned. Emphasis will be placed on a number of complex tax issues relating to PEs, such as non-discrimination, e-commerce, triangular cases and the problems surrounding agency PEs. The latest OECD developments and PE issues that can arise from business restructuring will also be examined.
This 2-day workshop explores the transfer pricing issues arising for a multinational group that operates in a number of jurisdictions around the globe. The workshop, which comprises of a rolling case study, considers the transfer pricing issues relating to the distribution, manufacturing, R&D, financing and management operations of the multinational group. These sessions are complemented by a session on dispute avoidance and resolution in the context of the case study.
This introductory course examines a wide range of tax implications that can arise when employees of multinationals move across border. Specific topics that may be relevant to expatriates such as the tax treatment of employee stock options and pension income are also covered.
This course is designed to give the participants a thorough understanding of the elements of EU law that are of practical importance with respect to the direct taxation of corporations. Course participants will gain an understanding of how to apply and use both the legislation and the case law of the EU in their daily tax advice and consultancy practice. The correlation between EU tax law, national tax law and double tax treaties will be examined and the work on harmful tax competition and current policy considerations will be discussed. Specific emphasis will be put on the Parent-Subsidiary Directive, the Interest and Royalties Directive and the Merger Directive, which have a great impact in the tax planning of European companies. In addition, this course offers the opportunity to examine the leading cases of the European Court of Justice and the latest developments with practitioners who are renowned in the field of EU law.
This course is designed to provide participants with an in-depth analysis of the legal and tax issues related to private equity and venture capital. More specifically, it describes the legal and tax aspects that have to be taken into account in making the investment decision and it gives a detailed overview of the structures and techniques used in daily practice.
