UnscheduledInternational 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.
Please note: This course is not currently scheduled. The price, program and instructors are detailed as per the previous course for information purposes only and may be subject to change.
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
SummaryThis is a 3-day advanced level course on international tax planning and structuring. You can join this Masterclass when:
Overview and Learning ObjectivesThe 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:
- 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.
Field of Study
- 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
TaxesWho 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 PrerequisitesThis 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