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OnlineITA105 Passive Income

This course is an essential tool to understanding the role tax treaties play in cross-border passive investments. We will take an in-depth look at dividends, interest and royalties, capital gains and technical service fees.
 
Type:
Online Tax Courses
Language:
English
Level:
Intermediate
Price:
EUR 499 / USD 674 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
 
Ordering multiple courses: to order more than one online course please view our instructions.

 

ITA105 Passive Income

Learning objectives

After completing this course you will be able to:

 

  • Explain the basic treaty distributive rules for income from immovable property, dividends, interest, royalties and capital gains and when these rules are applicable
  • Define the various tax treaty rules that may be applicable to technical services fees
  • Categorize the similarities and differences in the tax treaty treatment of various types of passive income
  • Apply the distributive rules to payments of passive income, including when they are derived by permanent establishments and when the payments are under non-arm's length terms
  • Define the areas of potential difficulty in connection with the application of the tax treaty rules for passive income

Level
Intermediate

Delivery method
QAS Self study

 

Field of study
Taxes

Course review
This course was last reviewed mid-2015

Pre-requisites

This course introduces the tax treaty rules that may be applicable to cross border passive income such as income from immovable property, dividends, interest, royalties, capital gains and technical services fees. Participants should be familiar with the basic principles of tax treaties in addition to the domestic law of at least one country, in particular as it relates to the taxation of cross-border income. The course builds on the basic ideas through to the more complex concepts and so participants, particularly those with limited knowledge of tax treaties, are recommended to first complete the course ITA101 "Fundamentals of Tax Treaties”.
 
While this course is suitable for practising professionals, it is also very useful as additional study material in preparing for the CIOT examination - Advanced Diploma in International Taxation (ADIT – Paper 1). Further information about this qualification can be found at the ADIT website.
 
No advance preparation is needed for this course.

 

Study time

 

  • Audio lessons: 4.5 hours
  • Self study: 8.5 hours (includes video)
  • Further reading (optional): 15 hours
  • Extra:  video interview with international tax expert

Access to the course is granted for a period of 8 weeks.

Continuing Professional Education (CPE)

The recommended CPE points for this course are as follows:

  • NASBA (The National Association of State Boards of Accountancy, US) - 11 points
  • CIOT (The UK Chartered Institute of Taxation) – 13 points
  • NBA (Nederlandse beroepsorganisatie van accountants) - 13 points

The International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website.

In addition, International Online Tax Courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect.

Read more information on CPE points and accreditation for International Tax Courses.

For more information regarding administrative policies such as complain and refund, please contact IBFD International Tax Training via email. Please note that once access to an online course has been granted, a refund will no longer be possible.

Order this course now by selecting 'Register Online' above.

 

  • Introduction to passive income
  • Income from immovable property
  • Dividends
  • Interest
  • Royalties
  • Technical fees
  • Capital gains
  • Introduction to further issues

Authors:

 
  •  
    Shee Boon Law is Head of Knowledge at DLA Piper’s International Tax Group, where he is responsible for promoting and representing the technical expertise of the International Tax Group to...

 

Other Contributors:

 
  •  
    Séverine Baranger is a Policy Analyst at the OECD-hosted Global Forum on Transparency and Exchange of Information for Tax Purposes. Until October 2013, she was a tax advisor at Loyens &...
  • Joel Lachlan Cooper is Co-Head International Transfer Pricing Group at DLA Piper, based in London, United Kingdom. He provides clients with a fresh perspective on complex transfer pricing matters...
  • Jan de Goede
      Prof. Jan J.P. de Goede, Senior Principal, Tax Knowledge Management, has held several positions at IBFD including Director of the Knowledge Centre. He performs various academic, teaching...
  • Rita Szudoczky has a PhD from the Amsterdam Centre of Tax Law of the University of Amsterdam and works at Loyens & Loeff as a know-how specialist. She lectures at the University of...
  •  Joanna C. Wheeler
    Dr Joanna Wheeler is a senior member of the IBFD academic group and is currently seconded to the University of Amsterdam (UvA) for a large portion of her time. She is the director of the advanced...
  • Wim Wijnen is Counsel to the Academic Chair of IBFD. He is also a teacher of International Tax Law at Libera Università Internazionale degli Studi Sociali in Rome, Italy and a part-time...