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Overview

We are delighted to present the fourth edition of our Masterclass on selected issues on international taxation and transfer pricing masterclass from an African perspective. The course will provide a unique learning platform for African tax practitioners and will precede the IBFD CSAT Africa Tax Symposium. In recent years, the international tax order has been changing steadily and rapidly as several tax developments have been and are being undertaken by, inter alia, the UN, OECD, ATAF, and different jurisdictions and with direct corollary to professionals needing continuous updates to stay in the loop. Implementation of some international tax aspects are also causing practical challenges to tax practitioners and tax administrations alike. 

This two-day intermediate level course aims to provide African tax professionals with practical and comprehensive coverage of the most important issues in international taxation and transfer pricing.

The IBFD CSAT Africa Tax Symposium will take place at the same location from 29-31 May 2024. 

Topics Covered

• Current developments in International Taxation – Implications for Africa
• Implementation of the Global Minimum Tax: Practical Approaches and Implications 
• Taxation of Cross-Border Payments: Challenges and Future Trends in Tax Treaty Application
• Taxation of Cross-Border Services: Trends and Challenges 
• Transfer Pricing and Intra-Group Services 
• Entitlement to Treaty Benefits: The Concept of “Beneficial Ownership” and Related Controversies 
• Modern Tax Planning Strategies: Implications and Risks 
• Practical Case Studies

The two days sessions will be supported by illustrative examples and prominent cases. In due course, participants will have the opportunity to discuss with instructors and peers the relevance and practical impact of the various issues on investment flows in Africa and on their daily work.

A brief overview is set out below. 

Day 1: Monday, 27 May

On Day 1 we will examine current issues and recent developments in international taxation and the practical trends and challenges on taxation of cross border business activities with a focus on Africa. Since a large part of the current international tax development evolve around addressing the tax challenges of the digitalized and globalized economy, our first session sets the scene by addressing recent tax developments that have been and are being undertaken by the UN Committee of Experts on International Cooperation in Tax Matters and the OECD/G20 Inclusive Framework on BEPS. Such developments include, inter alia, taxation issues regarding the digitalised and globalised economy in the form of cross border business services, and progress on the implementation of the two-pillar solution focusing on Pillar one Amount A and other alternatives if Amount A fails as well as the impact of Amount B in addressing transfer pricing problems in Africa. 

We have dedicated a full session to discuss the salient features, practical applications and status of the implementation of Pillar 2 Global Anti-Base Erosion Model Rules (GLoBE rules) with global minimum effective tax rate of 15% and analyse compliance issues within the ambit of the Global Minimum Tax Rules. 

Subsequently, will examine the present challenges and future trends regarding taxation of cross -border payments from tax treaty perspectives, by focusing among other things on the practical problems that taxpayers and tax administrations are facing concerning cross border payments, the tax treaty issues thereon and recent developments and future trends considering the subject to tax rule (STTR) as proposed separately by the OECD and UN. 

Finally, we will close our Day 1 sessions by addressing the trends and challenges of the taxation of cross border services in which we will discuss, among other things, the key categories of cross border services, tax treaty and domestic law issues, qualifications conflicts and recent developments.  

Day 2: Tuesday, 28 May

On Day 2 we start our discussion by examining the controversies evolving around transfer pricing aspects of intra-group services. In this session we will address, among other things, the key considerations and determining factors in dealing with intra- group services, areas of controversies and practical challenges, available mechanisms to address transfer pricing risks and to prevent and resolve disputes and will share insights from selected court cases. We will also discuss entitlement to tax treaty benefits focusing on the concept of beneficial ownership (BO) and the controversies surrounding it. This session will discuss the significance and meaning of BO concept from tax treaties perspective and examine the practical interpretation and application of the BO concept in different jurisdictions based on selected key court cases with insights from diverging tax jurisprudences, and the relevance of BO in the aftermath of some anti abuse measures in tax treaties, for instance, the limitation on benefits (LoB) rule and the principal purpose test (PPT) rule. 

Subsequently, we examine modern tax planning strategies and their implications as well as risks considering recent developments in international taxation. In this session we will examine prominent tax planning schemes in view of key anti - tax avoidance measures at national and international level resulting from BEPS 1.0 with 15 Actions recommendations and the effect of such schemes under BEPS 2.0 with the two-pillar solutions. We will also examine recent trends concerning tax planning such as substance and operational considerations and we will provide concluding remarks on the future of tax planning. 

Finally, the course ends with a session dedicated for case studies and group discussions in light of the two days courses and the practical experiences of the participants. 
 

Learning Objectives

After completing this course, you will be able to:

• Comprehend and define the importance of current developments in international taxation and transfer pricing to their daily practices.
• Identify the practical applications of Pillar 2 global minimum tax rules and the impact on foreign investment flows and its resulting effect in tax practices in Africa
• Analyse the practical challenges and future trends regarding taxation of cross-border payments from tax treaty perspective including potential impact of the subject to tax rule (STTR) as developed by the OECD and the UN, separately
• Identify and define different categories of cross-border services, conflicts of qualifications and challenging issues under domestic law and tax treaties.
• Apply transfer pricing rules on intra-group services by comprehending key considerations and determining factors that help avoid risks and prevent disputes.
• Explain the practical effect of beneficial ownership requirement in tax treaties and the controversies on its interpretation and application and its effect in the aftermath of the LoB and PPT rules. 
• Evaluate modern tax planning strategies after  BEPS 1.0 anti-abuse measures (15 Actions) and BEPS 2.0 two-pillar solution (Pillar 1 and 2) and recent trends
• Differentiate various ways and techniques in dealing with practical tax case
   

Instructors

Field of study

Taxes

Who should attend

The course is suitable for professionals, such as tax managers and directors, in-house tax and accounting specialists, practitioners in tax advisory firms, and government officials/experts who deal with international tax or transfer pricing in Africa and wish to gain a deeper technical understanding of relevant domestic tax law, tax treaty, and transfer pricing developments. 

Course Level and Prerequisites

This is an intermediary level course. Participants taking this course will be expected to have a good understanding of at least one national tax system, transfer pricing and the fundamentals of tax treaties.

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 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 are: 14

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

This year's venue will be the Safari Park Hotel.

Kasarani off Thika Road, 
Nairobi, Nairobi 00100, Kenya
Tel: +254 709 732000
reservations@safariparkhotel.co.ke

Accommodation

Please book your accommodation with a hotel of your choice directly. IBFD does not handle any hotel reservations.

If you wish to book accommodation at the Safari Park Hotel, please click on the following link and log in to receive IBFD’s special rate during the course:

Safari Park Hotel – Booking link IBFD 
Please log in (top right) with username: IBFD, password: Sph##2024

A list of alternative hotels in Nairobi is provided in this document.

Please make your own arrangements for travel from the hotel you are staying at to the venue and back. IBFD does not provide any shuttles. 
 

Disclaimer

• The programme of the masterclass is subject to minor changes, and IBFD reserves the right to apply changes to the line-up of speakers.
• IBFD reserves the right to cancel the masterclass due to low registrations. If the minimum number of participants is not met and IBFD decides to cancel the masterclass, we will inform participants by 6 May 2024 at the latest. In that unfortunate case, 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, in the event that IBFD cancels the masterclass due to low registrations by 6 May 2024. 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.