Masterclass - Navigating Selected Issues in International Taxation and Transfer Pricing

We are delighted to present the fifth edition of our Masterclass on Navigating Selected Issues in International Taxation and Transfer Pricing. The course will provide a unique learning platform for African tax practitioners and will precede the IBFD CSAT Africa Tax Symposium.

It is axiomatic that the international tax order has been changing steadily and rapidly as several tax developments have been and are being undertaken at global, regional and national levels, with the corollary being that professionals need continuous updates to stay in the loop. This two-day intermediate-level course will, therefore, provide participants with a platform to learn, share and debate the most pressing issues in international taxation and transfer pricing.

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Date26 - 27 May 2025
VenueKigali Serena Hotel
LocationKigali, Rwanda
Early bird discountEarly Bird 10% until 15 April 2025
Payment via InvoiceIf you wish to pay via bank transfer, please contact our customer service team at info@ibfd.org

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Description

The course aims to keep professionals updated on the rapidly changing international tax order and the practical challenges these developments present.

 

Day 1: Monday, 26 May 
On Day 1, we will review the latest in international taxation and transfer pricing, focusing on progress with Pillar One Amount A and B, and Pillar Two global minimum tax rules. We will highlight challenges faced by developing countries and discuss UN tax initiatives, including updates to the UN Model Tax Convention and issues related to natural resources, digital economy taxation, and practical transfer pricing guidance. 

We have two sessions dedicated to the practical implementation of Pillar Two global minimum tax (GMT) rules, examining their scope, application order, affected entities, and safe harbour provisions. We will also explore post-GMT scenarios, tax competition, potential disputes, and compliance issues. 
Finally, we will address trends and challenges in taxing the digitalized economy, discussing key issues, domestic law and treaty options, practices in Africa, and potential solutions.

Day 2: Tuesday, 27 May 
On Day 2, we will explore current trends and challenges in taxing capital gains and offshore indirect transfers. We will cover the taxation of capital gains on direct and indirect asset transfers, insights from court cases, and considerations based on existing tax treaties and model conventions. 

Next, we will address practical challenges and strategies for selecting relevant comparables in transfer pricing analysis. This session includes key features of comparables, trends in selection, and insights from important court cases. 
The course concludes with practical case studies and group discussions, reflecting on the two-day material and participants' experiences. 

Throughout the sessions, illustrative examples and notable court cases will support the content. Participants will engage with instructors and peers to discuss the relevance and impact on businesses in Africa and their daily work.

 

Topics Covered

  • Current issues in international taxation and transfer pricing around the globe
  • Pillar Two – Global Minimum Tax: Practical implementation and key insights
  • Pillar Two – Global Minimum Tax: Key considerations, challenges and relevant compliance aspects from an African perspective
  • Taxation of the Digitalized Economy: Emerging trends and key challenges in Africa context
  • Taxation of Capital Gains and Offshore Indirect Transfers: Current trends and challenges
  • Selection of Relevant Comparables in Transfer Pricing Analysis: Practical Challenges and Winning Strategies
  • Case studies    

Learning Objectives

After this masterclass, the participants will be able to:

  • Define the importance of current developments in international taxation and transfer pricing to their daily practices
  • Comprehend the practical implementation of Pillar Two global minimum tax rules and the impact on foreign investment flows and its resulting effect on tax practices in Africa
  • Analyse key considerations, practical challenges and future trends regarding the application of the global minimum tax rules
  • Identify and define current trends and challenging issues regarding taxation of the digitalized economy  
  • Evaluate characteristic features and key considerations on the taxation of capital gains and indirect transfer of assets under domestic law and tax treaties  
  • Apply the best strategies in selecting comparables for transfer pricing analyses and define key considerations to avoid tax risks and prevent disputes
  • Differentiate various ways and techniques of dealing with practical tax cases 

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 treaties 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 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: 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

Kigali Serena Hotel, Kigali, Rwanda

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.