The Tax Treaties course will:
- Explain what treaties and tax treaties are
- Reviews the object & purpose of tax treaties – including MLI changes
- Give a good understanding of the OECD, UN & US model tax treaties
- Explain how treaties avoid double tax
- Provide a thorough understanding of specific treaty articles
- Cover residency and permanent establishments in detail
- Explain the traps and opportunities found in the treaty articles dealing with immovable property, business profits, dividends, interest and royalties as well as in the area of double tax relief
- Explain the intricacies of applying treaties to hybrid entities and unusual business forms
- Explain how treaties are interpreted and the impact of important cases on treaties
- Explain the interaction between treaty articles
- Cover ‘beneficial ownership’ and current law and practice in this area in several jurisdictions
- Touch on various countries’ digital services tax, ‘Google Tax’, diverted profits tax and the like – and their relationship with treaties
- Provide a good understanding of the MLI and the tax treaty aspects of ATAD as well as other anti-avoidance measure affecting treaties
- Provide an excellent forum for networking and sharing practical experiences and insights