Advanced International Taxation Law Training Course

Course Objectives
Upon completing this International Taxation Law course successfully, participants will study:
• Planning taxes in light of the latest international case laws
• Dealing with the impact of tax anti-avoidance measures
• Managing substance to dismantle anti-avoidance tools – how to get the right level of substance
• Setting up taxation structures to effectively plan indirect transfers of real estate
• Recent case law and domestic law developments concerning anti-abuse measures from around the globe
Course Outline
FUNDAMENTALS OF TAX TREATIES
• The international tax environment
• Double tax relief
• How tax treaties operate
• Responsibility and expansion of model treaties and commentaries
• The making of tax treaties
• Eligibility to treaty benefits
• Interpretation and dispute resolution
FUNDAMENTALS OF VALUE ADDED TAX
• Introduction to value added tax
• Essential attributes of taxable supplies – goods and services
• Taxable persons
• Taxable amount – VAT rates and exemptions
• Place of supply – Goods
• Place of supply – Services
• Deduction and recovery of input tax
• Administrative elements of VAT
DESIGN OF CORPORATE TAX LAW SYSTEMS
• Introduction to Corporate Income Tax
• Tax chargeable base & rate
• Tax chargeable base & rate: tax havens & preferential tax regimes
• Tax chargeable base & rate: intercompany dividends & capital gains
• Taxation of corporate groups
• Withholding Tax
• Interest deductions and other financial payments
PRINCIPLES OF INTERNATIONAL TAXATION & TAX TREATIES
• Controlled foreign company regimes
• Hybrid mismatches
• Introduction to international tax law
• Double taxation
• Distributive rules
• OECD & BEPS
• Hybrid mismatch arrangements & preventing treaty abuse
INTERNATIONAL TAX PLANNING
• Introduction to international tax planning
• Formal aspects of tax planning
• Substantive aspects of tax planning
• Tax structuring of holding and financing activities
• Tax structuring of manufacturing and distribution activities
• Tax planning for intangible property
TRANSFER PRICING
• What is transfer pricing?
• Why is it important?
• The arm’s length principle: legal framework
• Traditional transaction methods
• Transactional profit methods
• Business restructuring
• Apple case
• Outro – Transfer Pricing
• Transfer pricing of intangibles
DOUBLE TAXATION RELIEF
• Introduction to double taxation relief (DTR)
• Exemption
• Credit – creditable amount
• Credit – credit limits and excess credits
• Deduction
• Income computation
• Losses
• Legal basis of DTR
• Persons eligible for DTR
• Foreign income eligible for DTR
• Taxes eligible for DTR
• Problem areas

Methodology
The training methodology integrates lectures, interactive discussions, collaborative group exercises, and illustrative examples. Participants will acquire a blend of theoretical insights and hands-on practical experience, emphasizing the application of learned techniques. This approach ensures that attendees return to their professional environments equipped with both the competence and self-assurance to effectively implement the acquired skills in their responsibilities.
DATE:
1ST BATCH: 28th – 31st Jan, 2025
2ND BATCH: 1st – 4th July, 2025