ibfd international tax academy · (pe). practical issues, such as vat and profit allocation, will...

IBFD, Your Portal to Cross-Border Tax Expertise

IBFDInternational Tax AcademyStudy with the best to be your best

Choose from:

• Open courses

• In-house training

• Online learning

2012 / 2013

Register online at www.ibfd.org/courses

2 Order online at www.ibfd.org/courses

IBFD International Tax Academy

Make the best use of your timeWith IBFD ITA training formats tailored to your needs

Your time is precious, valuable, and needs to be used with optimum efficiency. If you want to grow in international taxation in a way that matches your professional life and personal requirements, choose from IBFD’s range of course types:

�� Open courses – at IBFD’s head office in Amsterdam and other international locations�� In-house courses – at your premises or another location of your choice�� Online courses – high-quality, interactive online training and study solutions

Study with a world leaderEstablished in 1989, IBFD ITA is recognized globally as a provider of in-depth, up-to-date training on international tax and other specialized topics.

Enjoy a rich and valuable learning experienceOur courses draw on the expertise of tax practitioners from around the world. These training solutions will give you a thorough understanding of relevant principles and concepts, plus the skills to apply them in practice.

Share in proven success for professionals worldwideJoin over 1,300 international participants each year who participate in IBFD ITA courses. Whether they ar from advisory, multinational, government or global organizations, all our participants benefit from solutions designed to meet individual needs.

�� Choose from a range of introductory, intermediate and advanced-level courses�� Acquire a thorough understanding of principles and concepts in just a few days�� Participate in group discussions and case studies�� Network with international instructors and participants�� Supplement learning with extensive printed or online documentation and resources�� Obtain certificates for CPE/CPD purposes�� Access to complementary resources through a documentation platform

�� Training for larger groups in a convenient and cost-effective way�� Courses arranged at your premises or an international location of your choice�� Choose from ITA’s extensive range of courses�� Customize or combine courses to meet your learning requirements�� Access to online platform with complementary documentation�� Obtain certificates for CPE/CPD purposes�� Participate in group discussions and case studies

�� Meet your learning objectives without the time and cost of travel�� Choose specific courses to study, then determine your own schedule and pace�� Benefit from an interactive learning environment including audio-visual lessons, self-study assignments, quizzes and further reading�� Obtain certificates for CPE/CPD purposes�� Enterprise packages available to train organizations and departments at lower cost

Open courses In-house courses Online courses

For more information, please visit www.ibfd.org/courses or contact us: Open courses – [email protected], Online courses – [email protected], In-house courses – [email protected]

3Order online at www.ibfd.org/courses

IBFD International Tax Academy (ITA) Open, Online and In-house courses qualify for Continuing Professional Education (CPE) credits with several organizations including:

Professional Development

In addition, courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect. Contact the accrediting bodies directly in order to register your CPE credits.

CertificateAt the end of an open or in-house course, a personalized certificate of completion is issued to participants. IBFD ITA Online students can print their certificate on successful completion of the course and final test. The certificate indicates the hours of study and further reading included in the course and can be submitted to professional bodies for CPE/CPD points/credits, where applicable.

ACCA Global

BSB (UK) CIOT (UK)

IAB (Belgium)

ICAB (Barbados)

ITI(Ireland)

NASBA (US)

ODCEC(Italy)

RB (Netherlands)

SIATP(Singapore)

Association of Chartered Certified Accountants

Bar Standards Board The UK Chartered Institute of Taxation

Instituut van de Accountants en de Belasting-consulenten / Belgium Institute of Accountants and Tax Advisers (IAB-IEC Recognition nr. B0181/2010-09)

The Institute of Chartered Accountants of Barbados

Irish Taxation Institute

The National Association of State Boards of Accountancy of the US. (IBFD ITA is registered with NASBA as a sponsor of continuing professional education on the National Registry of CPE Sponsors.)

Milan Institute of Chartered Accountants

Register Belastingadviseurs / Registry of Tax Advisers

Singapore Institute of Accredited Tax Professionals

Registered as an approved course provider of ‘face-to-face’ training. Open and online courses are eligible for CPE credits.

Registered as an approved course provider. Open courses and a selection of online courses are eligible for CPE credits. For more information contact ITA. Registered as an approved course provider. Open and online courses are eligible for CPE credits.

Registered as an approved course provider. Open courses are eligible for CPE credits.

Registered as an approved course provider. Open courses are eligible for CPE credits.

Open and online courses are eligible for CPE credits.

Registered as an approved course provider. Open courses and a selection of online courses are eligible for CPE credits. For more information contact ITA.

Registered as an approved course provider. A selec-tion of open courses is eligible for CPE credits. For more information contact ITA.

Registered as an approved course provider. Open and online courses are eligible for CPE credits.

Open and online courses are eligible for CPE credits.


Introductory�� Interpretation and Application of Tax Treaties�� Principles of International Taxation�� International Taxation of Expatriates�� Summer Course – Principles of International and Comparative Taxation

Intermediate�� International Tax Aspects of Permanent Establishments�� Tax Treaties Negotiations Workshop�� Practical Application of Tax Treaties�� International Taxation of Oil and Gas and Other Mining Activities

Advanced�� Recent Case Law on Tax Treaties�� Tax Treaty Workshop

Introductory�� US Corporate Taxation�� NEW Corporate Taxation: Tax Treaties and EU Aspects

Intermediate�� NEW Principles of International Tax Planning�� Taxation of Holding Companies in Europe�� International Tax Planning for Multinational Enterprises�� Debt and Financial Restructuring�� Tax Risk Management�� International Tax Aspects of Private Equity

and Venture Capital�� International Tax Aspects of Mergers, Acquisitions and Corporate Finance�� NEW Recent Developments in International Taxation: US, EU and Tax Treaty Aspects

Advanced�� Innovative Financial Products

IBFD ITA Open Courses

Open courses offered by IBFD ITA

Choose from a range of introductory, intermediate and advanced-level courses:

Introductory�� Introduction to Transfer Pricing

Intermediate�� Principles of Transfer Pricing �� Transfer Pricing: Intangibles and Intra-Group Finance�� NEW�Transfer Pricing and Dispute Resolution:Aligning Strategy and Execution�� NEW�Taxation of Supply Chain Restructuring�� Transfer Pricing and Attribution of Profits to PEs�� Taxation of Supply Chain Management and Business Restructuring

Advanced�� NEW�Transfer Pricing Workshop

Introductory�� Introduction to European Value Added Tax

Intermediate�� European Value Added Tax – Selected Issues

Advanced �� European Value Added Tax Workshop

Tax Treaties Corporate Taxation

Transfer Pricing Indirect Taxation



IBFD ITA Courses

TAX TREATIES

�� Interpretation and Application of Tax Treaties – Introductory LevelThis course covers a wide range of tax issues that have to be addressed in interpreting and applying tax treaties, such as the concept of treaty residence and permanent establishment, attribution of profits to a permanent establishment, passive income, employment income, double taxation relief methods and non-discrimination principles. The course will provide participants with a framework for understanding the issues as well as opportunities to apply the knowledge acquired during the course in case studies.

�� International Taxation of Expatriates – Introductory LevelThis course is designed to give participants a thorough understanding of the tax implications associated with individuals who move cross border. The course examines the possible consequences of emigration under domestic law, the relevant provisions of the OECD Model Convention on Income and on Capital, and the interaction between domestic law and the OECD Model. Specific topics that may be relevant to expatriates, such as the tax treatment of employee stock options, pension income and exit taxes, are also covered.

�� Summer Course – Principles of International and Comparative Taxation – Introductory LevelThis course is designed to provide participants with the basic concepts and principles of international tax law. It examines the sources of international tax law, how those sources of law fit together, and the current issues of international tax law. The concepts and principles of international tax law are further applied to the practice of business structures and planning. The course includes many case study sessions to ensure that the concepts discussed within the course are well understood from a practical perspective.

�� Principles of International Taxation – Introductory Level This course is designed to provide participants with the essentials of international taxation. The first three days are dedicated to the fundamental concepts relevant to the interpretation and application of international tax treaties. This introduction provides participants with the conceptual tools to fully grasp issues discussed on Day 4 and Day 5. Day 4 deals with the principles of transfer pricing and how these principles apply to intra-group services. Day 5 provides an overview of basic tax planning structures and an insight into the application of the most common anti-avoidance provisions.

�� International Tax Aspects of Permanent Establishments – Intermediate LevelThis course is designed to provide participants with an in-depth analysis of the concept of permanent establishment (PE). Practical issues, such as VAT and profit allocation, will be covered. This will be combined with the use of case studies to ensure that participants leave the course with the confidence to apply what they have learned. Emphasis will be placed on a number of complex tax issues relating to PEs, such as non-discrimination, e-commerce, triangular cases and the problems surrounding agency PEs. The latest OECD developments and PE issues that can arise from business restructuring will also be examined.

�� Tax Treaties Negotiations Workshop – Intermediate LevelGiving you the confidence to successfully negotiate tax treaties is the principal objective of this workshop. We will discuss various provisions that can be included in tax treaties based on the OECD and UN Models and the implications of these on the scope and application of tax treaties, the distributive rules for different categories of income, elimination of double taxation and special administrative rules. These discussions will be put into practice in a treaty negotiation workshop.

Please note our Early Bird Discount offer on page 11.


�� Practical Application of Tax Treaties – Intermediate LevelThis course deals with the application of double tax treaties in complex scenarios and with the issues that can arise in those circumstances. The course covers the application of the dual resident tiebreaker rules, the application and classification issues involving royalty and other cross-border passive income, the application of the PE concept and the attribution of PE profits, triangular cases, entity taxation and treaty anti-abuse rules.

�� Recent Developments in International Taxation – Intermediate LevelThis 3-day intermediate to advanced-level course provides participants who deal with double tax treaties on a regular basis with an update on the recent developments in the application and interpretation of tax treaties.

�� International Taxation of Oil and Gas and Other Mining Activities – Intermediate Level This course provides participants with an in-depth analysis of the international tax issues related to oil and gas and other mining activities. More specifically, it covers how these activities are dealt with under tax treaties and how tax treaties impact the taxation of enterprises engaged in such activities and their employees.

�� Tax Treaty Workshop – Advanced LevelThis workshop provides participants with an in-depth understanding of the treaty rules and methodologies for permanent establishments and triangular cases. Participants will be guided through a series of complex case studies aimed at highlighting the problems concerning permanent establishments, attribution of PE profits and triangular cases.

�� NEW�Recent Case Law on Tax Treaties – Advanced Level This 3-day advanced-level course provides participants who deal with double tax treaties on a regular basis with an in-depth understanding of the important international developments including recent OECD updates and case law, and how these developments impact the application of double tax treaties.

TRANSFER PRICING

�� Introduction to Transfer Pricing – Introductory LevelTransfer pricing is one of the most important international tax issues faced by multinational enterprises and tax administrations today. This 2-day course introduces participants to the fundamental principles of transfer pricing, the transfer pricing methodologies, and the application of these principles and methodologies. The course focuses on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.The delivery of the formal sessions is complemented by interactive case studies and practical examples.

�� Principles of Transfer Pricing – Intermediate LevelIt is often said that transfer pricing is not an exact science. Hence, to develop an understanding of transfer pricing principles and methodologies, consideration of their practical application is considered paramount. This 4-day course introduces participants to transfer pricing principles and methodologies and the application of these principles and methodologies to specific categories of intra-group dealing. These sessions are complemented by practical sessions that cover the application of the principles and methodologies. The focus of this practice oriented course is on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the issues that can arise in the application of these requirements.




�� Transfer Pricing: Intangibles and Intra-Group Finance – Intermediate Level Intra-group finance and intangible property dealings raise a range of complex transfer pricing considerations, which, if not adequately addressed, may result in significant risk exposure for a multinational. This 3-day course explores the application of transfer pricing principles to intangible property and to intra-group financing arrangements. The course covers the identification and classification of intangible property, royalty rate determination, cost sharing/contribution arrangements and an introduction to intangible property valuation techniques. Intra-group finance is covered by firstly discussing the importance of transfer pricing in relation to such dealings and then considering the practical application of transfer pricing methodologies to intra-group loans, guarantee fees and cash-pooling arrangements, and the practical approaches to managing the transfer pricing aspects of intra-group financing transactions. The delivery of the formal sessions is complemented by practical examples, and the course concludes with an interactive case study to consolidate participant learning.

�� Transfer Pricing and Attribution of Profits to PE – Intermediate Level The attribution of profits to permanent establishments (PEs) is currently one of the most debated topics in international tax circles. For more than a decade the OECD has been running a project on this issue, the work of which has changed the landscape of PE profit attribution.

�� Transfer Pricing Workshop – Advanced LevelThis 2-day workshop explores the transfer pricing issues arising for a multinational group that operates in a number of jurisdictions around the globe. The workshop, which includes a rolling case study, considers the transfer pricing issues relating to the distribution, manufacturing, R&D, financing and management operations of the multinational group. These sessions are complemented by sessions on dispute avoidance and resolution in the context of the case study.

�� Transfer Pricing and Dispute Resolution: Aligning Strategy and Execution – Intermediate Level This course addresses the complexity, valuation and administrative nuances, and cultural effects of resolving transfer pricing disputes. It provides participants with an in-depth coverage of the varied approaches to administrative resolution of transfer pricing disputes, specific alternative dispute resolution mechanisms and the effective use of advance pricing agreements, correlative adjustment procedures in the event of transfer pricing adjustments, cross-border exchange of information concerns, and how to proceed litigation if all else fails administratively. Unfortunately, today, litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct.

�� NEW�Taxation of Supply Chain Restructuring – Intermediate Level Multinational enterprises (MNEs) are continuously exploring opportunities to reduce costs and increase efficiency by streamlining processes and relocating functions across countries. In designing organizational structures, the possibility of pursuing tax savings is often one of the drivers in the decision-making process. As a result, MNEs normally consider the use of tax-efficient supply chain management structures when reorganizing their business or setting up establishments in new markets.


CORPORATE TAXATION

�� Taxation of Holding Companies in Europe – Intermediate LevelThis course provides an overview of the tax planning goals and objectives of a multinational group and an in-depth discussion of the use of EU holding companies and their role in financing and intellectual property structures. The course addresses the tax aspects to be taken into account when establishing holding companies in Europe, sets forth the criteria to be used in evaluating and selecting a holding company location, and offers an overview of the domestic legislation of countries that are often used as a location to establish holding companies within Europe.

�� Tax Risk Management – Intermediate LevelThis course is designed to provide participants with an in-depth analysis of the tax issues related to tax risk management. In response to a number of widely known corporate failures, the tax risks call for the effective management of such risks. Companies in different industries and in different regions of the world administer the process of managing tax risks in a wide variety of ways. The course provides an in-depth analysis of the legislation rules and the approach of both tax authorities and governance bodies with respect to tax risk management.

�� International Tax Aspects of Private Equity and Venture Capital – Intermediate Level This course provides participants with an in-depth analysis of the legal and tax issues related to private equity and venture capital. More specifically, it describes the legal and tax aspects that have to be taken into account in making investment decisions and it gives a detailed overview of the structures and techniques used in daily practice.

�� International Tax Planning for Multinational Enterprises – Intermediate LevelThis course provides participants with a practical understanding of international tax planning tools for multinational enterprises. In particular, the course will cover tax planning techniques and trends for their holding, financing, manufacturing, R&D and selling activities. The course will conclude with discussions of the relevant domestic and tax treaty anti-avoidance rules.

�� International Tax Aspects of Mergers, Acquisitions and Corporate Finance – Intermediate Level�This course is designed to provide participants with an in-depth analysis of the tax consequences arising from cross-border M&A and corporate financing transactions. The course covers the full scope of M&A, focusing on various techniques that should be in place in order to successfully take over a business. The most common structures used to efficiently finance an M&A deal from a tax perspective will be presented too. Further, an in-depth analysis of the tax issues arising from the implementation of the most common cross-border corporate financing techniques will be provided.

�� Debt and Financial Restructuring – Intermediate LevelThis course provides participants with an in-depth analysis of the legal and tax issues related to debt and financial restructuring in the context of the current financial crisis. More specifically, it describes the legal and tax aspects that have to be taken into account in making restructuring decisions and gives a detailed overview of the structures and techniques used in daily practice.



�� Innovative Financial Products – Advanced Level This course is designed to provide participants with in-depth analyses of the regulatory, accounting and tax issues arising from the use of hybrids, derivatives and other innovative financial products such as repos and securities lending transactions. Participants will acquire structured background knowledge of the concepts and principles of these innovative products and their role in cross-border corporate financing and tax planning techniques.

�� NEW�US Corporate Taxation – Introductory Level This course provides participants with an overview and a good understanding of the complex US tax system, with particular emphasis on international aspects. The main focus of the course is on corporate taxation.

�� NEW�Recent Developments in International Taxation: US, EU and Tax Treaty Aspects – Intermediate LevelThis 3-day intermediate-level course provides participants who deal with international taxation on a regular basis with a comprehensive update on the recent developments in the field, with a particular focus on the US, EU and tax treaty aspects, including the changes to the OECD and UN Model Tax Conventions and Commentaries.

�� NEW�Corporate Taxation: Tax Treaties and EU Aspects – Introductory Level This course provides a thorough understanding of the main issues involved in the application of income tax treaties and EU tax law with respect to direct taxation of corporations. Specific emphasis will be put on the relevant provisions of the OECD and UN Model Conventions, the EU Treaty and the EU Directives. Recent developments in the application and interpretation of those provisions will be analysed in depth. The course will be interactive, with case studies to enable participants to gain confidence in applying the skills acquired during the course.

�� NEW�Principles of International Tax Planning – Intermediate LevelThis course is aimed at analysing the fundamentals of international tax planning in a structured and consistent manner, deepening the knowledge of tax planning techniques of the participants. Although the course will focus on practical cases, domestic legislation will not be addressed in specific detail.

�� Corporate Financing – Tax Issues – Introductory Level The aim of this introductory course is to provide participants with an in-depth analysis of the tax issues arising from the implementation of various cross-border corporate financing techniques. Corporate finance deals with financial decisions made by businesses including those on how to finance investments and if such financing should take the form of debt or equity, if returns to shareholders should be in the form of dividends or otherwise, etc. Further, increasing levels of cross-border investments have made cross-border deals much more common and the majority of such deals are financed using various types of financial instruments.


“ITA is our preferred course provider because it offers an extensive range of highly technical quality courses.” Ernst & Young, Brazil

“… attending several ITA courses confirmed IBFD’s well-founded reputation.”FedEx Express, EMEA


�� Indian Corporate Taxation – Introductory LevelThis course is intended to give participants an overview and a good understanding of the Indian tax system (including changes that are to be introduced by the new Direct Tax Code) and its terms and concepts, with particular emphasis on the wide range of corporate/international tax issues that have to be addressed when investing in India. The main focus of the course will be on corporate taxation and investment structures.

�� Indonesian Corporate Taxation – Introductory LevelThis course is intended to give participants an overview and a good understanding of the Indonesian tax system and its terms and concepts, with particular emphasis on the wide range of corporate/international tax issues that have to be addressed when investing in Indonesia. The main focus of the course will be on corporate taxation and investment structures.




INDIRECT TAXATION

�� Introduction to European Value Added Tax – Introductory LevelThis course is designed to provide participants with a framework of the most important VAT principles and issues which anyone dealing with value added tax in the European Union is confronted with and needs to understand. The course will end each day with a case study to enable participants to gain confidence in applying the skills acquired during the course.

�� European Value Added Tax – Selected Issues – Intermediate LevelThis course focuses on complex issues that can arise for international businesses in the application of value added tax in the European Union. The course will cover intra-Community (triangular) supplies of goods and services, consignment stock and warehousing arrangements, and VAT planning and control.

�� European Value Added Tax Workshop – Advanced LevelThis interactive workshop consists mainly of case studies and is designed for participants who are experienced in the principles of value added tax in the European Union and who want to train themselves further on important issues of particular complexity or interest for VAT practice in internationally operating businesses and industry.

“I found the ITA course on Residence very valuable in that the course focuses on the relevant aspects of residence from a local and international perspective, and it provides the student with a range of very useful training options, e.g. an audiovisual presentation, professional articles on the topic for the student’s review, and quizzes. ”Christian Wiesener, Tax Advisor, South Africa

‘’We have identified ITA as a course provider with an international reputation and orientation that proves to be a centre for knowledge-sharing among professionals. Throughout the years we have found that ITA offers highly valued courses with regard to technical contents and we have received an excellent feedback on the high level of professionalism and care for our delegates.’’ Pirola Pennuto Zei & Associati, Italy

Early Bird Discount A 30% discount* will be applied to registrations received 60 days or more before the commencement of 2012 courses in Amsterdam and Christ Church (Barbados). For courses in Kuala Lumpur, Beijing, Dubai, Shanghai and Singapore, a 20% discount* will be applied to registrations received 30 days or more before the commencement of the course. *non-cumulative with membership or any other discount

For course dates, please refer to our calendar, pages 21-22, or our website, www.ibfd.org/courses.


IBFD ITA Online

© 2009 IBFD International Tax Academy

SLIDE 16 OF 32 PAUSED 00:04 / 01:22

ITA101 Fundamentals of Tax Treaties - Lesson 2b (11:30/26:49)

SearchNarrationThumbnailsOutline

How tax treaties operateLesson overview

Royalties taxation under domestic lawRoyalties – treaty allocation of taxing rights

Allocating taxing rights under the treaty

Royalties – treaty allocation of taxing rightsRoyalties – treaty allocation of taxing rights

Interest – treaty allocation of taxing rights


Interest – treaty allocation of taxing rightsIncome from immovable property – domestic

Income from immovable property – domestic Income from immovable property – domestic

Treaty allocation rules - comparison

Categories of income in the OECD ModelTreaty allocation rulesSource state thresholds

Source state thresholdsSource state thresholdsSource state thresholds

Employment income threshold

Business profit threshold

Business profit thresholdPermanent establishment

Overview of the OECD Model Convention


Interest – taxation under domestic law


Residence State Source State

RENT

Income fromimmovable property

May tax May tax

Art. 6INCOME FROM IMMOVABLE PROPERTY

OECD Model Tax Convention on Income and on Capital

(1) Income derived by a resident of a Contracting State from immovable property(including income from agriculture or forestry) situated in the other Contracting State maybe taxed in that other State.

OECD

IBFD ITA Online, an integral part of IBFD’s International Tax Academy, is proud to be your source of the highest quality, interactive online training solutions. Excellence is our top priority, and we accomplish it by carefully crafting our courses and study solutions in collaboration with international tax experts combining their theoretical and practical experiences.

Online coursesOur courses are designed to help broaden knowledge on issues involving cross-border taxation and provide flexible, results-oriented training to tax professionals anywhere in the world.View more on pages 13-15. Online study guidesOur study guides provide reading material to those who wish to enhance their knowledge and skills related to the world of international taxation. The study material is taken from a wide range of international sources.View more on pages 16-17.

Currently available

�� ITA101 Fundamentals of Tax Treaties�� ITA102 Residence�� ITA103 Permanent Establishments�� ITA104 Employment and Related Income�� ITA105 Passive Income�� ITA106 Business Profits

�� ITA Online Transfer Pricing Study Guide

�� ITA107 Fundamentals of Value Added Tax

Tax Treaties Transfer Pricing Indirect Taxes


IBFD ITA Online Courses

(1) The international taxenviroment

(4) Role and developmentof model treaties

(3) Revision quiz 1

(6) Revision quiz 2

(2a) Double taxation relief (2b) How tax treatiesoperate

(5a) The making of taxtreaties

(5b)Eligibility to treatybenefits

(7b) Interpretation anddispute resolution(7a) Case studies

(8a) Policy considerations (8b) Expert comment

Welcome Lessons

(1) The international tax environment

Core study time: 55 min

ITA Online, Your portal to International Tax TrainingITA101 Fundamentals of Tax Treaties

This Site

Inte

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Aca

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y ONLINE - Domestic law as the foundation of international tax

- Features with cross-border impact- Overview of international tax environment- Introduction to key concepts

Audio Lesson

Lesson 1: Audio Lesson (A handout is available for you to print and make notes while following the audio lesson. Click here for the handout.)

Study time: 30 min

Study time: 20 min

Play audio lesson

Glossary

Revise key terms Revise key terms covered in this lesson. For each term you can look up a definition in the IBFD International Tax Glossary.Click here

Handout

Conceptual map of factors influencing the international tax environment View/print a conceptual map of the international tax environment, consisting of three levels.

Click here

Expert Comment

Interview with Michael Lennard (Part 1) This is the first part of an interview between Joanna Wheeler and Michael Lennard where he talks about international organizations active in the area of international tax law and their aims in this respect. Click here Study time: 5 min

International Tax Academy Online Courses > ITA101 Fundamentals of Tax Treaties

Structure of online courses

�� Each course comprises sequentially displayed core lessons. Following their order, you will be guided through the course in an organized and logical fashion.�� Additional optional lessons (highlighted in light blue) cover specialized topics to expand your knowledge in the subject areas.�� To facilitate your learning, print a handout of each audio lesson. This will help you take effective notes during the course and enhance your learning experience.

Audio-visual lessons combine text with spoken narration and animated images. Play, pause and rewind to control your own study pace, and revisit the materials at any point.

Separate tabs enable you to view each lesson’s outline or miniature slides, follow word-for-word narration of the audio, and search for a particular phrase in the lesson you may want to review.

Self-study directs you to supplementary reading materials to further develop your understanding of the course topics.

Access relevant excerpts from the OECD and UN Model Tax Conventions, related Commentaries, court cases, or other applicable IBFD publications with just one click on the link and avoid time-consuming searches.

In the course of the self-study process, you will encounter a series of thought-provoking questions to reflect on.

Online course features

© 2009 IBFD International Tax Academy

SLIDE 16 OF 32 PAUSED 00:04 / 01:22

ITA101 Fundamentals of Tax Treaties - Lesson 2b (11:30/26:49)

SearchNarrationThumbnailsOutline

How tax treaties operateLesson overview

Royalties taxation under domestic lawRoyalties – treaty allocation of taxing rights


Royalties – treaty allocation of taxing rightsRoyalties – treaty allocation of taxing rights



Interest – treaty allocation of taxing rightsIncome from immovable property – domestic

Income from immovable property – domestic Income from immovable property – domestic

Treaty allocation rules - comparison

Categories of income in the OECD ModelTreaty allocation rulesSource state thresholds

Source state thresholdsSource state thresholdsSource state thresholds

Employment income threshold

Business profit threshold

Business profit thresholdPermanent establishment

Overview of the OECD Model Convention


Interest – taxation under domestic law


Residence State Source State

RENT

Income fromimmovable property

May tax May tax

Art. 6INCOME FROM IMMOVABLE PROPERTY

OECD Model Tax Convention on Income and on Capital

(1) Income derived by a resident of a Contracting State from immovable property(including income from agriculture or forestry) situated in the other Contracting State maybe taxed in that other State.

OECD

Articles 23A and 23B of the OECD Model

In the OECD Model, there are two alternatives for the article on double tax relief. Art. 23 A iswritten for states that mainly use the exemption method, and Art. 23B is written for states thatmainly use the credit method.

Articles 23A and 23B of the OECD ModelSource: IBFD Tax Treaties Database

Copyright © 2009 IBFD International Tax AcademyThis document is protected by copyright of IBFD or its licensors. Only registered course participants aregranted access to this document. Without written permission of IBFD it is not permitted to reproduce, store,forward or make available on a network or to any third party, this document or any information that isavailable on the site. Click here for full Copyright Notice.

Click here

Self Study


Case studies help you put theory to practice and apply the concepts learned to real-life scenarios. Hands-on exercises will challenge you to answer various questions and subsequently provide feedback on your performance.

Further readings give you access to IBFD’s journals and other professional literature written by international subject experts, which will help you advance your proficiencies and expand your knowledge of the topic.

Quizzes incorporated in the lessons will help you test your understanding of the concepts and apply them in different scenarios.

In addition, revision quizzes will test your mastery of the course material and help you identify your strengths and weaknesses so that you can go back and re-learn material if necessary.




Expert comments give access to short video interviews and discussions with experts in the field, providing insights into broader issues related to the subject.

Additional documentationAt the start of each course you will have access to written instructions on how to proceed with the course. For additional guidance consult our frequently asked questions (FAQ) section on www.ibfd.org/courses.

An electronic binder of course materials, including presentation handouts, articles and further reading, may be downloaded for future reference after completion of the course.

Benefits of our online courses

Continuing Professional EducationOur online courses are accredited with various professional organizations and allow you to fulfil your CPE requirements. For more information on CPE, view page 3 of this overview.

How to sign up for a free trial lesson or get more information All courses are available in English. A selection is also available in Chinese or Spanish. Please note that a trial lesson is available. View courses currently available on page 12. For pricing and order information, view page 17.

Enjoy the broad spectrum of content developed by top tax experts from around the world. Put theory to practice with relevant examples and case studies.

Access a course 24/7 from anywhere in the world and revisit sections of the course whenever you wish. No need for extra software.

Set your own schedule and study pace. Focus on less familiar concepts and skim over well-known materials.

Stay engaged with our highly interactive multimedia lessons and receive immediate responses and feedback

Train your organizations, departments or individuals and save time and money on travel and books. Access to diverse and relevant materials will help you master the subject areas.

Quality

Convenienceand flexibility

Control

Stimulation

Affordability

For more details on each course, to sign up for a free trial lesson, or to place your order, visit www.ibfd.org/Courses.


IBFD ITA Online Study Guides

Study guides give easy access to an extensive set of study materials from a wide range of international sources. They are an essential resource for professionals planning to build their expertise and knowledge of topics in cross-border taxation.

Online study guide features

Currently available study guide on page 12.

The study guides may prove useful for those preparing for the CIOT ADIT examination. A wealth of documentation includes articles, excerpts from books, relevant case law, examples of legislation from selected countries, internet links and/or audio lessons from the IBFD ITA online courses.

�� All study material is available online and allows for easy printing. �� The structure follows the syllabus of the CIOT ADIT examination�� Each study guide follows a logical sequence of topics.

Literature and additional references contain materials from a broad range of international sources such as the OECD, United Nations, European Commission, ICC and WCO.


IBFD ITA Online & Pricing Information

“I am very satisfied with the course because it significantly improved my knowledge about the concept of the residence in international taxation. When I started the course, I scored 70% on the revision quiz. After completing the course, I scored 100%!”Ludmila Mermerska, Transfer Income Tax Advisory OOD, Bulgaria

“The course has been enlightening. I have always been curious about international taxation, and this course has given me a clear overview of the inner workings of international taxation. The structure and design of the course makes learning easy and engaging.”Mohammad Firza Ahmad, Inland Revenue Authority, Malaysia

To place your order, visit www.ibfd.org/Courses. See pricing page on www.ibfd.org/Courses/Pricing.

For larger orders, an enterprise deal can be arranged. Please contact [email protected] or call + 31-20-554-0319 for more information.

Note: discounts are not cumulative.

Online courses

IBFD Members 20% discount on standard price

Single-course subscription EUR 499 / USD 674 standard price

5-course subscription (or more) 20% discount on standard price

Online study guides

IBFD Members 20% discount on standard price

Single subscription EUR 200 / USD 270 standard price

Pricing information


IBFD ITA In-House

For more information, please visit www.ibfd.org/courses, or contact us at [email protected] or tel. +31 20 5540160.

Join our clients; they include governments, leading advisory and multinational firms from around the world who have benefited from our tailored learning solutions.

Topics that matterIn-house courses cover a wide range of topics in international taxation.

We provide particular training for your staff on specific topics at the level that works best for participants: introductory, intermediate or advanced.We will schedule dates that are suitable for you and our instructors will come to the venue of your choice, saving you time, travel and accommodation costs

Tailored Solutions

Our learning solutions are complete – you will get presentations, interactive case studies, sharing of know-how, printed materials and access to a tailored online documentation platform with additional resources including articles, case law and legal documentation

Complete

Average cost of approximately € 750 per participant for groups of 25*

*may vary depending on topic, length of course and number of participants

Cost effective

Our learning solutions are delivered by experienced tax professionals who are also skilled instructors

Expertise

You will learn the most current tax developments that are practical and relevant to your work

Up to date

IBFD’s tailored learning solutions

IBFD’s International Tax Academy works together with you to provide a tailor-made solution to your training needs, according to your preferred topic, level and location.

Benefits

EU Tax Law

TransferPricing

Tax Treaties

CorporateTaxation

EuropeanVAT


Corporate�▪ Introduction to tax treaties�▪ Tax treaty interpretation�▪ Residence�▪ Permanent establishment concept�▪ Attribution of profits to PEs�▪ Investment and real estate income�▪ Payments for technology�▪ Treaty characterization issues�▪ Non-discrimination �▪ Triangular cases�▪ Partnerships and hybrid entities�▪ Anti-avoidance provisions and

treaty abuse�▪ Permanent establishments

�▪ Residence and dual residence�▪ Partnerships�▪ Treaty case law

Individuals (with Focus on Expatriates)�▪ Residence�▪ Employment income�▪ Pensions�▪ Private capital (passive income

received by individuals)�▪ Emigration/immigration issues�▪ Employee stock options

�▪ Introduction to tax planning�▪ Tax structuring through debt and

other financing activities�▪ Tax structuring through branches

and tax consolidation�▪ Tax structuring through hybrid

entities�▪ Tax planning for holding

activities�▪ Tax planning for intangibles�▪ Substantive tax planning –

business restructuring�▪ Hybrid financial instruments�▪ Derivatives �▪ Anti-avoidance rules

Corporate TaxationTax Treaties

IBFD ITA In-House

Examples of In-house topics:

�▪ OECD Transfer Pricing Guidelines for Multinational Enterprises

�▪ Article 9 of the OECD MTC�▪ Transfer pricing methods�▪ Comparability�▪ Documentation�▪ Administrative aspects�▪ Latest developments�▪ Transfer pricing and business

restructuring�▪ Intangibles�▪ Intra-group services�▪ Cost contribution arrangements�▪ Intra-group finance

�▪ Introduction to European value added tax

�▪ Special schemes�▪ Taxable amounts, tax rates and

exemption�▪ Deductibility of input VAT�▪ Imports and exports�▪ Intra-Community trade�▪ Current issues in the field of VAT�▪ Place of supply of services (new

rules from 2010)�▪ Financial services�▪ Immovable property

�▪ EU direct tax directives (Parent-Subsidiary Directive, Interest and Royalties Directive, Merger Directive)

�▪ EU fundamental freedoms and non-discrimination principles

�▪ ECJ case law on corporate taxation

Transfer Pricing European VAT EU Tax Law

Learn the basic concepts online at your own pace

Participants study online in their own time before attending live classroom training to consolidate and advance their learning

Combined with online learning solutions, live classroom sessions can be more focused on exploring practical application and more complex issues

Convenient

Efficient

Focus

Integrated learning solutionsOur tailored learning solutions can be combined with online learning


IBFD International Tax Academy

IBFD International Tax Academy closer to you

Apart from the courses run in the IBFD head office in Amsterdam, open offers courses at the following locations. �� Singapore, Singapore�� Kuala Lumpur, Malaysia�� Beijing, China�� Christ Church, Barbados�� Shanghai, China�� Dubai, UAE

Please refer to our course calendar, pages 21-22, to find a suitable course at your location of choice, or visit www.ibfd.org/courses for the latest agenda.


Course dates may be subject to change. Please refer to the IBFD website (www.ibfd.org) for updated information.

IBFD ITA Open Course Calendar

International Tax Planning for Multinational Enterprises�– Intermediate Level19-20 July 2012 | Amsterdam € 1,596 $ 1,995

Summer Course – Introductory Level20-31 August 2012 | Amsterdam € 4,500 $ 5,625

Principles of Transfer Pricing – Intermediate Level10-14 September 2012 | Kuala Lumpur MYR 5,400 $ 1,800

Introduction to European Value Added Tax – Introductory Level17-20 September 2012 | Amsterdam € 2,289 $ 2,861

Corporate Taxation: Tax Treaties and EU Aspects – Introductory Level24-27 September 2012 | Amsterdam € 2,289 $ 2,861

Principles of International Taxation – Introductory Level8-12 October 2012 | Amsterdam € 2,646 $ 3,308

International Taxation of Expatriates – Intermediate Level10-12 October 2012 | Christ Church € 1,200 $ 1,500

Taxation of Holding Companies in Europe – Intermediate Level15-17 October 2012 | Amsterdam € 1,764 $ 2,205

Taxation of Supply Chain Management and Business Restructuring – Intermediate Level22-24 October 2012 | Kuala Lumpur MYR 3,900 $ 1,300

Debt and Financial Restructuring – Intermediate Level25-26 October 2012 | Amsterdam € 1,596 $ 1,995

US Corporate Taxation – Introductory Level29-30 October 2012 | Amsterdam € 1,596 $ 1,995

Principles of International Taxation – Introductory Level5-9 November 2012 | Kuala Lumpur MYR 5,400 $ 1,800

Transfer Pricing and Attribution of Profits to Permanent Establishments – Intermediate Level7-9 November 2012 | Amsterdam € 1,943 $ 2,428

Principles of International Tax Planning – Intermediate Level12-16 November 2012 | Amsterdam € 2,646 $ 3,308

Application of Tax Treaties – Intermediate Level25-27 November 2012 | Dubai € 1,200 $ 1,500

European Value Added Tax – Selected Issues – Intermediate Level26-28 November 2012 | Amsterdam € 1,943 $ 2,428

International Taxation of Oil and Gas and Other Mining Activities – Intermediate Level26-29 November 2012 | Singapore $ 1,800

(Prices are exclusive of VAT)


(Prices are exclusive of VAT)

European Value Added Tax Workshop – Advanced Level29-30 November 2012 | Amsterdam € 1,596 $ 1,995

Principles of Transfer Pricing – Introductory, Intermediate Level3-7 December 2012 | Amsterdam € 2,646 $ 3,308

Tax Treaties Workshop – Intermediate, Advanced Level16-18 January 2013 | Christ Church € 1,260 $ 1,575

Course dates may be subject to change. Please refer to the IBFD website (www.ibfd.org) for updated information.

IBFD ITA Open Course Calendar


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By signing the registration form you agree with the terms and conditions and the cancellation policy of the IBFD International Tax Academy, as laid down on our website.Please return the completed form to the IBFD International Tax Academy, fax: +31-20-620 9397. Email: [email protected]

Clients in Asia, the Americas, the Caribbean, Australia and New Zealand will be invoiced in US$

IBFD ITA sends a free quarterly newsletter to its clients containing information about courses. Please tick the box if you do not wish to receive this.

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IBFD, Your Portal to Cross-Border Tax Expertise

Contact IBFD International Tax Academy

The world’s leading provider of international tax training solutions

IBFD International Tax AcademyIBFD Head OfficeP.O. Box 202371000 HE AmsterdamThe NetherlandsTel.: +31-20-554 0160Fax: +31-20-620 9397Email: [email protected]: www.ibfd.org

Victor van Kommer (Director Tax Services)Email: [email protected]

IBFD ITA Asia-Pacific Suite 22.03, Level 22, Centrepoint South No.1, the Boulevard, Mid Valley City Lingkaran Syed Putra 59200 Kuala LumpurMalaysia

Tel.: +6-03-2287 0709Fax: +6-03-2287 0729Email: [email protected]

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IBFD ITA OnlineTel.: +31-20-554 0181Fax: +31-20-620 9397Email: [email protected]

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