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.
Early Bird Discount: a 30% discount will be 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 objectivesSubstance has grown in importance as a consequence of the recent discussions from a domestic law perspective as well as from an EU (aggressive tax planning and harmful tax competition) and OECD (base erosion and profit shifting, BEPS) perspective. Countries such as the Netherlands, Ireland and Luxembourg have allegedly become subject to scrutiny by the EU Commission. As a result, these countries, such as the Netherlands, have responded by introducing substance requirements in their preferential tax regimes. Furthermore, countries are terminating their tax treaties with certain states because of the alleged misuse of those treaties by residents of third states (treaty shopping).Topics to be discussed in this course include “substance” in relation to tax residence, beneficial ownership, permanent establishments, limitation on benefits clauses, transfer pricing and patent boxes, the EU and OECD perspective on substance, relevant case law and the response from MNEs and trust companies to the changing environment.This is an interactive course with a maximum of 32 participants. Prior to the course, participants will be given access to an online platform which provides them with additional pre-reading material and supplementary material (e.g. legal documentation and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.Field of studyTaxesWho should attend?The course is suitable for practitioners in tax advisory firms, and tax specialists in commerce and industry.Course level and prerequisitesThis 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 preparationIn 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 educationRecommended 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 detailsThe 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
- Patent boxes and substance
- Substance and permanent establishments
- EU level
- TP and substance
- Beneficial ownership
- Limitation on benefits clauses
- Case study