Principles of International Business Taxation

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Cross-border trade and investment is crucial for many enterprises. One of the risks involved is potential double taxation. This course will provide participants with a thorough basis to confidently and correctly apply the key provisions of tax treaties regarding the different types of income derived by enterprises in order to avoid possible double taxation. The course will deal with important issues such as residence, permanent establishment, profit attribution to permanent establishments, investment income and capital gains and will also take a detailed look at the recent introduction of the Principal Purpose Test, a general anti-abuse provision in tax treaties.

Topics Covered

  • Introduction to international taxation
  • Residence
  • Basic rule permanent establishments
  • Other types of permanent establishments
  • Cross-border business activities
  • Attribution of profits to permanent establishments
  • Dividends, interest, royalties and fees for technical services
  • Anti-abuse provisions on dividends, interest, royalties and fees for technical services
  • Capital gains
  • Double tax relief
  • Principal purpose test

Learning Objectives

Skills practiced and developed during the course include:

  • Interpret and apply the tax treaty provisions relating to the various types of income of enterprises
  • Correctly interpret tax treaty terms
  • Identify the treaty residence of an enterprise including tiebreaker rules
  • Determine whether a non-resident enterprise has a permanent establishment in a state
  • Attribute income and expenses to a permanent establishment
  • Determine the amount of withholding tax due on cross-border dividends, interest and royalty payments
  • Apply the beneficial ownership concept
  • Allocate taxing rights regarding different types of capital gains
  • Determine the amount of double tax relief
  • Correctly apply the Principal Purpose Test

Read this sample case study to understand more about the type of topics and skills you will learn during this online course.

Delivery Method and Core Study Time

Online (QAS self-study)

Consists of 11 modules of approx. 1 hour video lessons each and case assignments, which help apply knowledge in practice. Two assessments are also included to test your overall understanding.

Field of Study

Taxes

Who Should Participate

The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry, government officials who regularly encounter issues related to cross-border taxation and anyone who desires to develop a comprehensive understanding of international taxation principles.

Prerequisites

This is an introductory-level course. Participants should have a basic knowledge of the domestic tax system of at least one country, specifically, taxation of foreign income derived by resident companies and domestic-source income received by non-resident companies. In addition, a basic understanding of the function of double tax treaties would be helpful, but the course will presume that course participants are new to dealing with tax treaties.

Advance Preparation

No advance preparation is necessary. All required study material is provided within the online training

Components of Training and Study time

This online course is divided into 11 modules, each consisting of videos of approximately 1 hour per module, case assignments and recommended reading materials.

Access to the online course is granted for a period of 4 months, from the date of ordering.

The course can be followed and completed by dedicating a minimum of five hours of study per week. Study materials included in the course will be accessible for the duration of the course only.

Completion requirements

To benefit from the learning experience for this training, completing all mandatory components is necessary to obtain your certificate. Upon access to the learning platform, the syllabus will indicate the exact completion requirements. Please also consult the FAQ for more information.

Continuing Professional Education (CPE)

International Online Tax Courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect.

International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Issues regarding registered sponsors may be submitted to the National. Registry of CPE Sponsors through its website: www.nasbaregistry.org. Recommended NASBA CPE credits for this course is: 22

Please consult the FAQ for more information. Regarding administrative policies such as complaint, cancellation and refund, please refer to our Terms and Conditions or contact info@ibfd.org.

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