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The Tax Treaties course will:

• Explain the types of treaties and of tax treaties
• 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 as well as hybrid financial instruments
• 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