29 Aug 2019 17:00 CETWebinar: Treaty Cases Update
- Broadcast time:
- EUR 85 / USD 99 (VAT excl.)
- Client offer:
Client offer: a 20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Bulk discount: a 20% discount will be applied to registrations received for 5 people or more made in one order.
- Webinar: Treaty Cases Update
Overview and learning objectivesAfter following this webinar you will have gained insight into the latest international tax treaty cases, their relevance and practical implications, and will be able to:
- better identify the key factors underlying the court decisions
- apply and interpret the treaty concepts discussed
Field of studyTaxes
Who should participateThe webinar is suitable for all tax professionals, including accountants, in-house tax managers and directors, lawyers, advisers, policymakers and government officials who wish to have a better understanding of the selected treaty cases and principles involved.
Course level and prerequisitesThis is an intermediate-level webinar. Participants are expected to have a general understanding of tax treaties and international taxation, including the OECD’s Model Tax Convention.
Advance preparationParticipation in this webinar does not require any preparation.
Interactive webinar - "Group Internet Based" (live webinar only)To safeguard the interactive nature of the webinar, a limited number of participants will be accepted. Early registration is therefore recommended. During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions or to complete short tests. Participants who follow the live broadcast will also have access to the on-demand version for a further 12 months from the live date.Date of live broadcast: 29 August 2019
On-demand webinarOn-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation or assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months from the date of registration and/or live broadcast.
Continuing Professional EducationMany accrediting organizations will grant CPE credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.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: www.nasbaregistry.org. Participants that follow the live webinar can claim 1.5 CPE credits while those following the on-demand version cannot claim the credits.
Webinar registration detailsIf you have any questions regarding following the webinar, technical requirements, and payments and cancellations, please consult our FAQ.
The cases to be addressed will include the following:
- Canadian Tax Court case of 22 August 2018 regarding the taxation of capital gains made on the sale of shares and application of the general domestic anti-avoidance rule under the Canada-Luxembourg DTT, case number 2018 TCC 152
- Korean Supreme Court cases: (i) of 27 December 2018 regarding beneficial ownership of royalties under the Korea-Ireland DTT, case number 2016Du42883 and (ii) of 15 November 2018 regarding beneficial ownership and domestic anti-abuse provision under the Korea-Hungary DTT, case number 2017Du33008
- Dutch Supreme Court case of 19 January 2018, regarding residence of a company and interpretation of the term “managed and controlled” under the Netherlands-Singapore DTT, case number 16/03321
- UK Court of Appeal case of 15 November 2018, regarding the relevance of UK domestic law in applying the business profits provision under the UK-South Africa DTT, Martin Fowler v. Commissioners for Her Majesty’s Revenue and Customs (HMRC), case number EWCA Civ 2544
- Dutch District Court case of 5 June 2019, regarding the consequences of recharacterizing interest under the Russian thin capitalization rules for the Netherlands-Russia DTT, case number ECLI:NL:RBNHO:2019:4803
- Cape Town Tax Court case of 12 June 2019, regarding the application of the most favoured nation clause under the South Africa-Netherlands DTT, ABC Proprietary Limited v. Commissioner for the South African Revenue Service, case number 14287