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16 - 18 Sep 2020International Tax Planning Masterclass

The course will focus on how to devise the building blocks of a comprehensive tax planning strategy utilizing the remaining tax planning opportunities and potential safe harbours following the implementation of the OECD/G20 BEPS Project, the recently implemented and proposed EU direct tax initiatives and US tax reform. 
 
Type:
Tax Courses
Language:
English
Location:
Amsterdam - The Netherlands
Level:
Advanced
Course code:
OC20TAPMC1
Price:
EUR 2,297 / USD 2,756 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
 
Early Bird Discount: a 30% discount will be automatically applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
 
 
International Tax Planning Masterclass
Summary
This is a 3-day advanced level course on international tax planning and structuring. You can join this Masterclass when:
 
  • your tax planning skills can do with a quick update on the latest global tax regulatory, legislative and case law developments in a practical and sometimes challenging manner;
  • you just want to learn new tax planning-related skills at an advanced level to differentiate yourself in the market;
  • you wish to obtain the latest know-how on international best practices; or
  • you simply want to be part of a reinvigorating professional experience.  
Overview and Learning Objectives
The course will focus on how to devise the building blocks of a comprehensive tax planning strategy utilizing the remaining tax planning opportunities and potential safe harbours following the implementation of the OECD/G20 BEPS Project, the recently implemented and proposed EU direct tax initiatives and US tax reform. The topics include:
 
  • PE tax planning in light of the latest international case law
  • ensuring beneficial ownership status for passive income in corporate structures
  • successfully dealing with the impact of new EU/US anti-avoidance measures
  • managing substance to dismantle anti-avoidance tools 
  • setting up structures to effectively plan indirect transfers of real estate and other assets
  • recent case law and domestic law developments concerning anti-abuse measures from around the globe
  • addressing the latest disclosure and reporting obligations
  • obtaining rulings and APAs
  • dispute resolution
Field of Study

Taxes

 
Who Should Attend?
The course is suitable for tax practitioners in advisory firms, tax specialists in commerce and industry, and government officials with at least 5 years of experience and cross-border responsibilities.
 
Course Level and Prerequisites
This is an advanced-level course. Participants will be expected to have a good understanding of the application of double tax treaties, transfer pricing issues and practical tax considerations that have an impact on international tax planning.
  • Avoidance of permanent establishment risks in light of current international case law
  • Obtaining tax treaty benefits - part 1: Ensuring beneficial ownership status
  • Obtaining tax treaty benefits - part 2: Ensuring compliance with the principal purpose test, limitation on benefits clause and other treaty and domestic anti-abuse measures
  • Outbound tax planning: The extraterritorial reach of EU, US and other domestic tax laws
  • Managing tax transparency measures and tax risk assessment
  • Dispute prevention: advance tax rulings (ATRs) and advance pricing agreements (APAs) post-BEPS.
  • Dispute resolution - part 1: Mutual agreement procedures (MAPS)
  • Dispute resolution - part 2: Arbitration in tax matters
  • Case study-based assignments
  •  
    Tamás Kulcsár is a Manager at IBFD’s Tax Services team, as well as contracted expert of the IMF, with over ten years of experience in international tax, transfer pricing and VAT...
  • Premkumar Baldewsing 
    Premkumar Baldewsing is a Principal Research Associate at IBFD. He has extensive experience in the (inter)national tax arena, including in senior in-house tax functions with financial...
  • Barry Larking is an international tax strategist providing guidance and commentary on global tax technical and policy developments. After graduating from Oxford University and working as a UK tax...
  • Soojin Lee is a Senior Research Associate at IBFD Tax Services. She is involved in government consultancy projects and in the development of training programmes for tax authorities and open...
  •  
    Mark Koek is Tax Counsel at LyondellBasell Industries, one of the world largest plastics, chemical and refining companies. He started his career in 1995 as an international corporate tax...
  •  
    Randall Fox is co-head of the International Transfer Pricing Group at DLA Piper, based in London. He assists clients with transfer pricing planning and controversy around the world, combining a...
  • Hans Mooij
    Hans Mooij, LLM, has spent almost a lifetime working in international tax, at virtually every level – policy, administration, advisory, litigation and academic. Since he started his own...