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UnscheduledTax Planning and Substance

This intermediate-level course aims at providing participants with an in-depth understanding of the substance issues related to international tax planning.


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.
Tax Courses
Amsterdam - The Netherlands
Course code:
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).
Tax Planning and Substance
Overview and learning objectives
Following recent discussions in the international tax arena, it is clear both from a domestic law perspective and from an EU and OECD perspective that the issue of “substance” has grown in importance and will remain highly important in the tax world for years to come. Countries such as the Netherlands, Ireland and Luxembourg have become subject to scrutiny by the EU Commission and have responded by introducing substance requirements in their tax regimes. Furthermore, countries are terminating tax treaties with certain states because of the alleged misuse of those treaties by residents of third states (treaty shopping). Thousands of tax treaties have, and will be, altered due to the BEPS Project and specifically due to the adoption of the Multilateral Instrument. Also, in the years to come, the EU Anti-Tax Avoidance Directive will be implemented and this will have a strong effect on international tax law within the internal market.

Topics to be discussed in this course include substance in relation to tax residence, beneficial ownership, the attribution of profits to permanent establishments, limitation on benefits clauses and the principle purpose test, transfer pricing and patent boxes, the EU and OECD perspective on substance, relevant case law, and the response from MNEs to the changing environment.

This is an interactive course with a maximum of 32 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.

Field of study
Who should attend?
The course is suitable for practitioners in tax advisory firms, and tax specialists in commerce and industry.
Course level and prerequisites
This is an intermediate-level course. Participants taking this course are expected to be familiar with the structure of at least one domestic tax system and to be aware of the common international tax planning techniques.
Pre-course preparation
In order to participate in this particular course, no advance preparation is necessary. However, for some courses, suggested reading materials will be made available on our online platform a few weeks before the start of the course.
Interactive course - "Group Live"
To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 32 participants will be accepted. Early registration is therefore recommended.
Continuing professional education
Recommended NASBA CPE points for this course: 12 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.
Course fee and registration details
The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.


  • Setting the scene - why is substance important in tax planning
  • Substance from an EU law perspective
  • Latest updates on patent boxes and substance
  • Transfer pricing and substance
  • Substance and the attribution of profits to permanent establishments
  • Substance and the beneficial ownership requirement
  • Anti-avoidance rules and substance
  • Case study


    Annemiek Kale is Global Head of Tax at Arla Foods amba in Denmark. Arla Foods is an international dairy cooperative that is the largest dairy producer in Scandinavia. The tax team of Arla...
  • Clive Jie-A-Joen
    Clive Jie-A-Joen works in the Financial Markets practice group of Simmons & Simmons LLP. His practice focuses on analysing, designing, planning, organizing, documenting and defending the...
  • 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...
    Bart le Blanc is a tax adviser at Norton Rose Fulbright LLP based in Amsterdam. He has over 17 years of experience in international corporate taxation, with a particular interest in the energy...
  • Ricardo Garcia Antón
    Ricardo Garcia Antón is a Senior Research Associate at IBFD. He was educated at the University of Seville, where he graduated in Law in 2002. He holds a master’s degree in...
  • Premkumar Baldewsing 
    Premkumar Baldewsing (AKA Boyke Baldewsing) is a Principal Research Associate at IBFD. He has extensive experience in the (inter)national tax arena, including in senior in-house tax...
    Marnix Schellekens is a Senior Research Associate in IBFD’s European Knowledge Group. After obtaining a master's degree in Economics and Tax Law from Groningen University in 2005, he...