Principles of International Business Taxation: In-Person Course
This two‑day, intermediate‑level course offers participants practical, hands-on insights into the domestic and treaty rules that shape the taxation of cross‑border business activities. The programme provides a clear and comprehensive overview of the key domestic tax provisions that trigger double taxation, as well as the mechanisms available under domestic law to relieve it. Participants will explore the core concepts found in double taxation conventions, focusing on their practical application, technical challenges, and impact on international business structures.
The course examines the determination of corporate residence, the creation of a taxable presence through Permanent Establishments (including their various forms), and the attribution of profits once a PE exists. Participants will also gain a structured understanding of treaty rules governing passive income – dividends, interest and royalties – along with capital gains, services performed abroad, directors’ fees, and the taxation of employees seconded across borders.
A key part of the programme addresses the interaction between domestic anti‑avoidance measures – such as abuse-of-law doctrines, thin capitalisation rules, and Controlled Foreign Company legislation – and treaty provisions. Treaty‑based anti‑abuse tools, including limitation‑on‑benefits clauses and the principal purpose test, will be explored with a focus on interpretation, compliance, and real-world implications.
Throughout the course, participants will work through case studies reflecting practical challenges faced by internationally active enterprises. By the end of the programme, they will have a solid operational understanding of the main OECD and UN Model Convention concepts and the skills to apply them confidently in real-life advisory and compliance scenarios.
The course also provides opportunities to engage with instructors and peers and discuss how these rules affect business operations globally.
Claim your 10% early‑bird discount before 9 August 2026. Your discount will be applied automatically at checkout when you register before the deadline.
- 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
After completing this course, 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.
- Birhanu Tadesse Daba, IBFD, the Netherlands
- Ruxandra Vlasceanu, IBFD, the Netherlands
- Luis Nouel, IBFD, the Netherlands
- Carlos Gutiérrez Puente, IBFD, the Netherlands
The course is suitable for:
Government officials, tax advisers, lawyers, accountants, in‑house tax directors, controllers, finance staff, and corporate tax professionals.
The Masterclass will be held at the IBFD Head Office, Rietlandpark 301, Amsterdam.
This is a foundation/intermediate-level course. Participants taking this course will be expected to have a solid understanding of the basic rules governing the taxation of business income as well as the tax implications relevant to employees and directors.
No advance preparation is necessary. All required study material is provided during the training.
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.
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. (National Registry of CPE Sponsors ID Number: 107989)
Number of CPE credits: 36
See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or please contact us via email.
- Field of Study - Taxes
- Delivery format: Group Live
- Course level: Intermediate
IBFD reserves the right to cancel this Masterclass up to 14 days prior to 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. Registered participants will receive a list of hotels that offer corporate rates.
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.
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