Topics Covered

• Introduction of cross-border taxation
• Tax treaty entitlement
• Residence
• Permanent establishment concept
• Attribution of profits to permanent establishments
• Income from the provision of services
• Investment income
• Capital gains
• Introduction to transfer pricing
• Taxation of employees and directors
• Tax treaty abuse and anti-abuse provisions

Learning Objectives

After this masterclass, the participants will be able to:

• Assess possible tax exposure of enterprises engaged in cross-border business activities
• Determine the residence of enterprises and employees for tax treaty purposes
• Determine whether there is a permanent establishment abroad
• Determine the allocation of taxing rights for different types of income of an enterprise
• Allocate the allocation of taxing rights for income derived by employees and directors
• Apply anti-abuse provisions in cross-border relations

Instructors 

Field of study

Taxes

Who should attend

The course is suitable for government staff, tax advisers, lawyers, accountants, in-house tax directors, controllers and finance staff.  

Course Level and Prerequisites

This is an intermediate-level course. Participants taking this course will be expected to have an understanding of the basic rules of the taxation of business income and that of employees and directors. 

Continuing Professional Education (CPE)

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. Recommended NASBA CPE credits for this course are: 18

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

Venue

to be confirmed, Amsterdam, Netherlands

Disclaimer

• IBFD reserves the right to cancel this Masterclass up to 1 month before the commencement date.
• The programme and line-up of speakers are subject to change.
• In the unfortunate event of the masterclass being cancelled, registered participants will receive a credit note by email at the email address provided and a full refund of the masterclass registration fee thereafter. In light of this, participants are kindly advised to make refundable travel and accommodation arrangements. Participants act at their own risk when booking non-refundable travel and accommodation arrangements. IBFD is not responsible for any loss incurred by participants who book non-refundable travel and accommodation arrangements.
• All bookings related to travel and accommodation, as well as local transportation, visas, vaccinations and travel insurance are at the participant’s own cost.