Double Tax Treaties in Corporate International Tax Planning
Speaker: Allan Cinnamon | CPD Hours: 6.0
OBJECTIVES
Tax treaties are a dynamic area of the international tax field. The most recent development on 7 June 2017 was the signing by 68 countries of The Multilateral Instrument (‘MLI’). It heralds a radical step change, facilitating the speedier way by which double tax treaties may be rapidly amended in order to comply with the BEPS project. Tax practitioners need to become thoroughly familiar with the MLI, as well as other crucial aspects of double tax treaties.
Illustrated with numerous practical examples, this course will cover pertinent cases, government actions and trends across the world that interpret and apply tax treaties to business operations.
The Double Tax Treaties in Corporate International Tax Planning course will be based on an analysis of the relevant articles of the OECD Model Treaty in relation to the crucial role they play in international tax planning for UK companies expanding and operating abroad; and for foreign companies doing business and investing into the UK. The treaty analysis will provide the building blocks for the application of treaties to the practical structuring of international operations, illustrated by considering specific treaties. The overarching impact of BEPS on double tax treaties will be fully covered.
CONTENT
- Treaty residence and dual residence
- Permanent Establishments and the BEPS proposals
- The Digital Economy and BEPS
- Dividends, Interest and Royalties
- Capital Gains
- Double Tax Relief
- Using the Non-Discrimination article
- Treaty shopping anti-avoidance and the BEPS measures
- The overall impact of BEPS, the MLI and the EU Tax Avoidance Directive
- Recent treaty cases
WHO SHOULD ATTEND
This course is suitable for those with some experience of the role of tax treaties in international tax planning, as well as those who want a basic but in depth understanding of how the model OECD treaty operates in practice.
Price £575 plus VAT
ADD
Looking to train your team or a group?
We can deliver any of our courses tailored to your needs at your offices or at a location of your choice.
Speak to one of our training experts
0844 873 2121
or request a call back
Find an alternative course
Courses running soon
December
"Very good and well presented course." Tim Buss, VAT for Accounts Payable course
Kathy Greenwell
Ellis Patents
"Everything was excellent - from enquiry to delivery of the course."
Salma Mohamed
Pen International
"Jacqueline was fantastic. Best course I have ever been on. Brilliant." Jacqueline Williams, Accounting Principles course
Heather Barker
British Land
"Small class and opportunity to discuss made course worthwhile."
Baldish Mandair
Specsavers Optical Superstores
"It was well-pitched and gave good references for further information. Example questions were good." Peter Hughes, IFRS Update course
Daniel Lally
Bouygues UK
"I would just like to say that I thoroughly enjoyed the course and found it extremely useful and informative. Steve Giles was extremely knowledgeable and very approachable so please do pass on my thanks. In addition, the lunch was fabulous!!" Steve Giles, Role of Non-Executive Directors course
Jayne Stokes
Port of London Authority
"The course was exactly as expected and really helped my understanding." Gwen Ryder, VAT 1 and 2 courses
Antonia Jones
The Motor Fuel Group
"Very good presenter. Good overview." Peter Hughes, Tax in Company Accounts IFRS course
Mamta Shah
Shell International
