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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.
Online Tax Courses
EUR 499 / USD 674 (VAT excl.)
Client offer:
20% discount for Global Tax Premier clients and 10% discount for Global Tax Explorer (Plus) clients.
Ordering multiple courses:
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


Delivery method
QAS Self study


Field of study

Course review
This course was last reviewed mid-2015


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 12 months, from the date of ordering. 

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


    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 the Counsellor to the Director’s Office at the Centre for Tax Policy and Administration (CTPA) at the OECD. She has more than 15 years of experience in...
  • Joel Cooper
    Joel Cooper is a Partner (Global Tax Desk – Transfer Pricing Controversy) at EY, based in London. He provides a fresh and pragmatic approach to international tax and transfer pricing by...
  • Jan de Goede
      Prof. Jan J.P. de Goede, Senior Principal, Tax Knowledge Management, reports directly to the CEO of IBFD and has held several positions during his 21 years at IBFD, including the role of...
  • Rita Szudoczky is an Assistant Professor at the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business (WU), Austria. Previously, she worked for IBFD...
  •  Joanna C. Wheeler
    Dr Joanna Wheeler is a senior member of the IBFD academic group. She established the advanced LL.M. programme in international tax law offered by the University of Amsterdam as a joint project...
  • Wim Wijnen is Counsel to the Director of the IBFD Knowledge Centre. He is Professor of International Tax Law at Libera Università Internazionale degli Studi Sociali in Rome (Italy), a...