There is continuing rise in cross-border activities across various industries due to globalization. Businesses are entering into significant commercial transactions and international projects through a range of structures and arrangements in order to gain access to new markets and resources and to share technical know-how. This programme provides participants with a broad overview of international taxation and how this has impact on cross-border activities, arrangements and transactions that involve the movement of persons, capital, goods and services across borders.
The programme begins with a very brief introduction to taxation, moving on to introduce key issues in international taxation as a result of globalization where residence, source, double taxation and double tax treaties will be examined. In the next section of the programme, participants are taken through tax considerations that must be kept in mind when one moves from doing business with another country to doing business in another country. Here, participants begin to examine key features of the operation of double tax treaties. As part of this section, participants will be taken through some of the ways in which differences in States’ tax systems can be exploited by taxpayers to minimize global tax liabilities, and the measures adopted by governments to combat perceived tax avoidance. Where appropriate, the concerns of tax authorities are addressed, and wherever possible, the course seeks to advance the reasoning behind the various anti-avoidance measures affecting international groups. Developments in international taxation in light of the OECD Base Erosion Profit Shifting (BEPS) Project are integrated into each topic as appropriate, where OECD’s main recommendations are set out and some explanation and comment on these are offered.
• Introduction to international taxation
• Concepts of source and residence, and a State’s right to tax
• Taxing individuals / individuals working abroad
• The double taxation problem – how does it arise
• Measures for elimination of double taxation
• An overview of the OECD Model Convention and the role of double tax treaties
• Main articles of the OECD Model Convention, their interaction and interpretation
• Permanent establishments
• Taxation of cross-border services
• Withholding tax - what is this and how does it arise
• Trading in multiple countries: structuring and tax planning strategies of multinational groups
• International tax avoidance and the improper use of tax treaties
• Transfer pricing
• Developments in international taxation – exchange of information agreements and OECD Base Erosion and Profit Shifting (BEPS) – an update on how these affect you