IBFD International Tax Training 2015

www.ibfd.orgIBFD, Your Portal to Cross-Border Tax ExpertiseIBFD, Your Portal to Cross-Border Tax Expertise

IBFD International Tax Training 2015International Tax Courses / Tailored Tax Courses / International Online Tax Courses

IBFD, Your Portal to Cross-Border Tax Expertise Courses at a Glance

2

See www.ibfd.org/training

for details on course date

and location.

IBFD International Tax Courses & IBFD International Online Tax CoursesChoose from a range of introductory, intermediate and advanced-level courses.

Tax Treaties

X Summer Course: Principles of International

and Comparative Taxation •

X Principles of International Taxation •

X International Taxation of Oil and Gas and

Other Mining Activities ••

X International Tax Aspects of Permanent

Establishments ••

X International Taxation of E-Commerce ••

X Tax Treaties - Selected Issues and Case

Studies ••

Individual Taxation

X International Taxation of Expatriates •

Corporate Taxation

X Principles of International Tax Planning ••

X International Tax Aspects of Corporate

Tax Planning ••

X Tax Planning and Substance ••

X International Tax Structuring for Multinational

Enterprises ••

X Tax Planning Workshop •••

X Base Erosion and Profit Shifting – Selected

Issues ••

X International Taxation of Oil and Gas and


X US Corporate Taxation ••

X International Taxation of Banks and Financial

Institutions ••

X International Taxation of E-Commerce ••

X International Tax Aspects of Mergers,

Acquisitions and Corporate Finance ••

Indirect Taxation

X Introduction to European Value Added Tax •

X European Value Added Tax – Selected

Issues ••

X European Value Added Tax Workshop •••

X Taxation of Supply Chain Restructuring ••

X International Tax Aspects of Permanent


X Transfer Pricing and Indirect Taxes ••

X VAT Considerations in M&A Transactions ••

Tax Treaties

X Fundamentals of Tax Treaties (English, Chinese,

Spanish) •

X Residence (English, Chinese) ••

X Permanent Establishments (English, Chinese) ••

X Employment and Related Income (English) ••

X Passive Income (English) ••

X Business Profits (English) ••

X NEW! Double Taxation Relief (English) •

Indirect Taxation

X Fundamentals of Value Added Tax (English) •

Corporate Taxation

X International Tax Planning (English) •

Transfer Pricing

X Fundamentals of Transfer Pricing (English) •

IBFD International Online Tax Courses

IBFD International Tax Courses

Transfer Pricing

X Principles of Transfer Pricing ••

X Taxation of Supply Chain Restructuring ••

X Transfer Pricing and Indirect Taxes ••

X Transfer Pricing and Intra-Group Financing ••

X Transfer Pricing and Intangibles ••

X Transfer Pricing and Attribution of Profits to

Permanent Establishments ••

X Transfer Pricing Risk Management:

Implementation and Monitoring ••

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TAX

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NEW

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TEXT

• Introductory

•• Intermediate

••• Advanced

IBFD, Your Portal to Cross-Border Tax Expertise Table of Contents

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Courses at a Glance 2

IBFD International Tax Training 4

IBFD International Tax Courses 6

How To Register 7

Tax Treaties and Individual Taxation 8

Corporate Taxation 8

Transfer Pricing 10

VAT / Indirect Taxation 11

Transfer Pricing Study Guide 13

IBFD International Online Tax Courses 14

Features 16

IBFD Tailored Tax Courses 18

IBFD Training Locations Worldwide 20

IBFD Course Accreditation 22

International Tax Courses

International Online Tax Courses


IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Training

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Courses designed to meet your professional needs

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Training

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“International Tax Training is our

preferred course provider because

it offers an extensive range of highly

technical quality courses.”

Ernst & Young, Brazil

As a busy tax professional your time is valuable. When you are considering training, the quality of the content, the length of the course and the location matter. IBFD recognizes this and offers a broad range of high-quality international taxation courses worldwide to enable you to achieve your professional objectives and personal goals. Our options include tax courses, online tax courses and tailored tax courses.

Recognized leader in tax education

Established in 1989, IBFD International Tax Training

is known globally as providing in-depth, up-to-date

training on international tax and other specialized

topics. These include tax treaties, transfer pricing,

corporate taxation and indirect taxation.

Benefit from an in-depth and practical

learning experience

Our courses draw on the knowledge of tax

practitioners from around the world who are experts

in their fields. The training solutions we offer will

give you a thorough understanding of up-to-date

principles and concepts along with the skills to

apply them in your daily practice.

Network with fellow tax professionals

from around the world

Hundreds of international tax professionals from

advisory, multinational, governmental and global

organizations participate in our tax courses each

year. The opportunity to meet and exchange ideas

with colleagues from around the world adds to the

course experience.

Amsterdam Moscow

SingaporeDubai

Kuala LumpurChrist ChurchBarbados

The Netherlands

South Africa UAE

Russia

Malaysia

Sao PauloBrazil

Johannesburg

Course locations

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses

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Topics that matter

Our international tax courses

cover a wide range of topics in

international taxation.

IBFD is recognized worldwide as a reputable learning centre in the field of international taxation. Our goal is to provide in-depth, up-to-date training on international tax and other specialized topics.

IBFD International Tax Courses

A unique learning experience

Drawing on the expertise of the multinational IBFD

research staff and tax practitioners from around the

world, the wide range of tax courses, online tax courses

and tailored tax courses give participants a thorough

understanding of the relevant principles and concepts,

as well as skills to apply these principles in practice.

A training solution to meet your needs

We train hundreds of participants each year from

advisory, multinational, government and other

organizations around the world. We offer a range of

training solutions designed to meet the various needs

of clients.

IBFD draws on the expertise of multinational research

staff and tax practitioners to offer top quality training.

X Knowledge: In-depth understanding of critical

principles and concepts in just a few days

X Interactive learning: Participation in group

discussions and case studies

X Course credits: Certificates for CPE/CPD

accreditation purposes

X Supplementary study material: Additional

learning with comprehensive printed/online

documentation and resources

X Networking: Meet and discuss current tax issues

with international instructors and participants

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses • How To Register

7

For enquiries about

registrations, contact IBFD

Customer Support at

[email protected] or

+31-20-554 0176.

How To RegisterTax Courses

Enrolment applications for international tax courses

are available via www.ibfd.org/training. There is no

closing date for enrolment but there are significant

discounts for early registrations. General terms and

conditions and information on Early Bird registration

are available via the IBFD website.

Course calendar

Information about all course dates and locations is

available in our course finder at www.ibfd.org/training.

Find the courses that are relevant to you and print the

selection of your choice through our print button.

Language

International Tax Courses are delivered in English.

Online Courses are offered in English, and selected

programs in Spanish and Chinese.

Accommodation

IBFD has reduced rates available at a number of

nearby hotels in Amsterdam. Details of hotels are

included with the confirmation of enrolment. For

courses held in other locations worldwide, IBFD

makes an effort to negotiate special room rates for

course participants.

Course location

All courses take place at IBFD’s premises in

Amsterdam unless otherwise indicated. The office

is 30 minutes from Schiphol Airport and easily

accessible by public transport and car. Detailed

address and travel information will be sent with the

confirmation of enrolment.

Course fees

Course fees include all course materials

including books (where applicable) and additional

documentation in print or online. At the course

location in Amsterdam participants will be able to

access the Tax Research Platform. Daily lunch is

provided but accommodation is at the expense of the

participant.

Course size

Each course has a maximum number of participants,

ensuring personal attention and lively group

interaction.

Enquiries

Contact International Tax Courses directly for

more information at +31-20-554 0157 and

[email protected] or visit www.ibfd.org/training.

Certificates

At the end of each course a personalized

certificate is issued to each participant. The

certificate indicates the hours of study and can

be submitted to professional bodies for CPE/

CPD credits, where applicable. IBFD online

course students can print their certificate from

the course platform after successful completion

of the program.

Register online at www.ibfd.org/training

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses • Tax Treaties and Individual Taxation

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Tax Treaties and Individual Taxation

Our Tax Treaties and Individual Taxation courses

are designed for:

X Tax advisers

X Accountants and tax lawyers

X In-house tax managers

X International tax executives

X Tax directors

X Government officials and tax inspectors

Summer Course •

Need a solid base to start your career in international

tax? This course will provide a foundational knowledge

covering the main areas of tax and give you the

confidence to achieve more in international tax.

This course covers:

X Interpretation and application of international tax

treaties

X Treatment of cross-border income under tax

treaties

X Principles of transfer pricing

X VAT

X EU tax law

X An overview of basic tax planning structures

X The application of anti-avoidance provisions

Principles of International Taxation •

Need a good base to start your career in international

tax? This course will provide the essential knowledge

you need and give you the confidence to achieve

more in international tax.

This course covers:

X Interpretation and application of international

tax treaties

X Treatment of cross-border income under tax

treaties

X Principles of transfer pricing

X An overview of basic tax planning structures

X The application of anti-avoidance provisions

International Tax Aspects of Permanent


The concept of permanent establishments is

central to many of the international tax risks

and opportunities associated with cross-border

business activities. Participants will gain an in-depth

understanding of the concept and practical issues,

such as the allocation of profits and VAT aspects,

related to permanent establishments.

This course covers:

X The concept of permanent establishments

X Attribution of profits to permanent establishments

X Permanent establishments and EU VAT aspects

X Non-discrimination and triangular cases

X Permanent establishments and business

restructuring

International Taxation of E-Commerce ••

Are you struggling to make sense of the international

debate on the taxation of e-commerce? This

course will help you find a way through the maze of

international debate and look at how to deal with

corporate income tax, withholding taxes and value

added tax aspects of e-commerce.

This course covers:

X Tax treaty characterization of e-commerce

transactions

X Entitlement to tax the income from e-commerce

transactions

X Entitlement to levy VAT on e-commerce transactions

X Recent developments with respect to the taxation of

the digital economy

Corporate Taxation

Our Corporate Taxation courses are designed for:

X Tax practitioners


X Tax directors

X Accountants



Principles of International Tax Planning ••

Learn the latest trends and issues in corporate

international tax structuring. Experts in this course will

discuss the fundamentals of international tax planning

in the context of global concerns about base erosion

and profit shifting.

This course covers:

X Key concepts in international tax planning

X Hybrid and derivative financial instruments

Early BirdDiscount

See page 12


for details on course dates

and location.

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses • Corporate Taxation

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X Tax structures involving the use of holding and

finance companies, branches, tax consolidation

and hybrid entities

X Supply chain structuring

X Tax planning related to R&D activities and

intangibles

International Tax Aspects of Corporate Tax

Planning ••

International developments in tax treaties and transfer

pricing may have a significant influence on your

corporate tax structures. This course will give you the

latest “All You Need To Know” in three days.

This course covers:


X Tax planning for treasury operations

X Intangibles and R&D activities

Tax Planning and Substance ••

Substance in tax planning has grown in importance

as tax administrations increase their focus on transfer

pricing and base erosion and profit shifting issues.

Experts will share their practical experience in

handling different aspects of substance requirements.

This course covers:

X Tax residence and substance

X Substance in trust companies

X Substance and permanent establishments

X Transfer pricing and substance

X Beneficial ownership and limitation on benefit clauses

X EU and OECD aspects of substance

International Tax Structuring for

Multinational Enterprises ••

Tax professionals who are involved in managing and

advising multinationals need to have an appreciation

of the tax opportunities and risks associated with

their global operations. This course brings you

insights from experts in the field of international tax

structuring for multinational enterprises.

This course covers:

X Tax planning opportunities and risks regarding

acquisition activities

X Holding and financing activities

X Post-acquisition structuring of manufacturing and

selling activities

X R&D activities and intangibles

X Disposition of foreign investments

Tax Planning Workshop •••

Come explore the ins and outs of international tax

planning in the BEPS era in a workshop environment.

You will learn the latest techniques and challenges by

working through a series of practical examples based

on real-life cases.

This course covers:

X Treaty aspects of international tax planning

X Holding and financing activities

X E-commerce activities

X Transfer pricing aspects of international tax

planning intangibles


Base Erosion and Profit Shifting – Selected

Issues ••

Many tax professionals have asked themselves and

their colleagues what the OECD Action Plan on Base

Erosion and Profit Shifting (BEPS) means for their

businesses and the businesses of their clients. Attend

this course to find out and explore how BEPS may

affect your business.

This course covers:

X Treasury tax planning and BEPS

X Domestic and treaty anti-avoidance rules

X Hybrid mismatches

X E-commerce

X Intangibles

International Taxation of Oil and Gas and


This course is designed to provide participants with

in-depth analyses of international taxation issues

related to oil and gas and other mining activities.

This course covers:

X International tax considerations in the oil and

gas industry

X Permanent establishments

X Offshore exploration activities

X Treaty characterization of income in the oil and

gas industry

X Expatriate employees in the oil and gas industry

X Transfer pricing issues

• Introductory

•• Intermediate

••• Advanced



and location.

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses • Transfer Pricing

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US Corporate Taxation ••

Learn the foundations of the US international tax

system quickly. Whether your work relates to US-

based multinationals or multinationals with activities

in the United States, this course will help you

understand its complex international tax system.

This course covers:

X Terms and concepts in US tax systems

X Taxation of foreign corporations

X Double taxation relief

X Foreign activities of US corporations

X Tax planning strategies of US corporations

International Taxation of Banks and

Financial Institutions ••

International businesses of banks and financial

institutions are complex and fluid. Attend this course

to learn from the experts about the associated

international tax risks and how to manage them.

This course covers:

X Specific issues involving bank branches

X Withholding taxes

X Derivatives and structured financial products

X Financial transaction taxes

X FATCA

X Transfer pricing issues

International Tax Aspects of Mergers,

Acquisitions and Corporate Finance ••

Acquire an overview of taxation issues in mergers

and acquisitions (M&A) deals and learn how to

manage them. This course covers the business,

regulatory and tax issues at both the national and

supranational levels.

This course covers:

X Tax principles in M&A deals

X Tax due diligence

X EU law

X Acquisition tax planning

X Tax-efficient financing of M&A deals

Transfer Pricing

Our Transfer Pricing courses are designed for:

X Lawyers

X Accountants

X In-house transfer pricing managers

X Transfer pricing advisers


X Tax directors


Principles of Transfer Pricing••

This transfer pricing course focuses on major transfer

pricing issues and concerns that all professionals

involved in transfer pricing will face.

This course covers:

X Transfer pricing methodologies

X Business restructuring

X OECD/UN Guidelines

X Documentation requirements

X Transfer pricing risk management

X Dispute resolution

X Different types of intercompany transactions

X Intellectual property

X Indirect taxes

Taxation of Supply Chain Restructuring ••

In order to remain competitive, companies need to

continually evolve and re-examine their business

models, expand their geographic footprint, integrate

acquisitions, and transform their operational structures.

This course covers:

X Tax-effective supply chain transformation

X OECD Transfer Pricing Guidelines

X Restructuring of intangibles

X PEs

X Indirect taxes

This course is a must in particular for:

X Economists

Transfer Pricing and Intra Group

Financing ••

This course addresses transfer pricing issues related

to intra-group financing transactions. Theory will be

demonstrated through examples and case studies. A

tax director of an MNE will share his/her best practices.

CourseAccreditation

See page 22

88% of our course participants

say that the course met their

expectations.

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses • VAT / Indirect Taxation

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This course covers:

X Intercompany loans

X Guarantees

X Cash pooling

X Factoring

Transfer Pricing and Intangibles ••

Transfer pricing and intangibles is now one of the

most important topics in transfer pricing. Theory will

be illustrated with examples and case studies.

This course covers:

X Definition of intangibles

X CCAs

X Innovation regimes in Europe

X Characterization issues and valuation

This unique, top-level course on transfer pricing

and intangibles is a must in particular for:

X Corporate tax and intellectual property legal

counsel

X Intellectual property and licensing executives

Transfer Pricing and the Attribution of Profits

to Permanent Establishments ••

In this course two worlds meet: transfer pricing and

permanent establishments. Theory is illustrated with

examples and case studies.

This course covers:

X Identifying a PE

X Attribution of profits to PEs

X Pricing of intra-entity dealings

X Business restructurings

X E-commerce

X BEPS

Transfer Pricing Risk Management:

Implementation and Monitoring •••

Transfer pricing is under ever more scrutiny

from tax authorities around the world. New and

further tightened regulations and legislations are

implemented. It is essential to identify, prioritize

and manage your risks, and constantly monitor and

review those risks. Theory will be illustrated with

examples, case studies and some best practices.

This course covers:

X Tax accounting

X Audits

X Transfer pricing control framework

X Transfer pricing dispute resolution

X The impact of BEPS

Transfer Pricing Workshop•••

The workshop is organized around a case study. The

workshop will enable participants to discuss issues

with colleagues and specialists on transfer pricing.

The case study covers the following topics

X Distribution

X Manufacturing

X R&D

X Services

X Intra-group financing

X Intellectual property

X Indirect taxes

VAT / Indirect Taxation

Our Indirect Taxation courses are designed for:

X Tax practitioners


X Tax directors

X VAT consultants

X Accountants and tax lawyers



Introduction to European Value Added Tax •

This course is designed to provide participants with

a framework of the most important VAT principles

and issues which anyone dealing with VAT in the

European Union is confronted with and needs to

understand. Theory is illustrated with examples and

case studies.

This course covers:

X Taxable persons

X Goods and services

X Place and time of supply

X Taxable amount – VAT rates

X Exemptions

X Deduction of input tax

X Immovable property

X Imports and exports

X Administrative obligations

X Intra-Community trade

• Introductory

•• Intermediate

••• Advanced

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses • VAT / Indirect Taxation

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and location.

European Value Added Tax – Selected

Issues ••

This course focuses on complex issues that can

arise for international businesses in the application

of VAT in the European Union.

This course covers:

X Recent developments and current issues in the

field of VAT

X Intra-Community (triangular) supplies of goods

X Cross-border services

X Consignment stock and warehousing

arrangements

X VAT planning and control

European Value Added Tax Workshop •••

This interactive workshop consists mainly of case

studies. It is particularly designed for participants

who are experienced in the principles of VAT in the

European Union.

This course covers:

X Immovable property transactions

X Online supplies of digital goods and services

X Financial services

X Manufacturing and selling activities of

multinational enterprises

VAT Considerations in M&A Transactions ••

This workshop introduces the general tax principles

arising when entering into M&A transactions in

a number of jurisdictions, focusing on the VAT

implications of various M&A scenarios. The sessions

will be led by tax experts in the fields of M&A and VAT.

This course covers:

X General tax principles of M&A transactions

X VAT issues for seller, acquirer and target

X Target and acquirer meetings

X Discussing the deal and recent developments

Introduction to VAT including Cross-Border

Supplies, Financial Services and Real

Estate •

This course is designed to provide participants with a

framework of the most important VAT principles and

issues which anyone dealing with VAT worldwide is

confronted with and needs to understand.

This course covers the following specific issues:

X VAT issues in the specific areas of financial services

and real estate

X A discussion of the VAT systems in the Middle East

and North Africa including a comparison with the

European VAT Directives where relevant

X Section focusing on the VAT implications of cross-

border supplies and anti-avoidance and fraud issues

Early Bird Discount

A 30% discount* will be applied to

registrations received 60 days or more before

the commencement of courses, except for those

taking place in Singapore and Kuala Lumpur. For

courses in Kuala Lumpur 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

• Introductory

•• Intermediate

••• Advanced

IBFD, Your Portal to Cross-Border Tax Expertise Transfer Pricing Study Guide

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Register online at

www.ibfd.org/training

The Transfer Pricing Study Guide gives easy online access to an extensive set of study material from a wide range of international sources. It is an extremely useful resource for professionals planning to build their expertise and knowledge on the subject area of transfer pricing.

Transfer Pricing Study Guide

The study guide is an essential tool 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 online courses.

Online Study Guide Features

All study material is available online and

allows for easy printing.

X The structure follows the syllabus of the

CIOT ADIT examination

X The 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, Your Portal to Cross-Border Tax Expertise IBFD International Online Tax Courses

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IBFD is proud to be your source of the highest quality, interactive online training solutions. Excellence is our top priority. We accomplish it by carefully crafting our courses and study solutions in collaboration with international tax experts – designed to help you turn theory into practice.

IBFDInternational Online Tax Courses

“I very much appreciate the

ability to study a technical

course flexibly in my own time.

The course materials were

detailed and interactive so I was

interested throughout. I plan

to use further online courses in

future.”

Alayne Mowbray, European

Tax Accountant, Avanade

Europe Services Ltd, UK

What we offer

X Interactive learning environment including

audio-visual lessons, self-study assignments

and quizzes

X Courses that can be adapted to your schedule

and pace. All courses available in English;

selected courses in Spanish and Chinese

X A way to achieve your learning objectives

without the time out of the office and cost

of travel

X Certificates for CPE/CPD accreditation

purposes

X Case studies to put theory into practice and

apply the concepts to real-life scenarios

X Enterprise packages to train entire organizations

and departments at a lower cost

Online Course benefits

X Quality: Expand your knowledge using the

broad range of high-quality content developed

by top tax experts from around the world

X Control: Focus on less familiar concepts and

skim over well-known materials

X 24/7 Learning: Access course material 24/7

from anywhere in the world and revisit any part

of the course whenever you wish. No additional

software is needed to access the program

X Motivation: The courses challenge you with

highly interactive multimedia lessons and provide

immediate responses and feedback, motivating

you to learn more

X Affordability: Save valuable time and money for

you and your organization

Tax Treaties

Fundamentals of Tax Treaties (English,

Chinese, Spanish) •

This course covers, in detail, the fundamental

concepts relating to tax treaties. It is highly

recommended for participants with no or limited

knowledge of tax treaties, or those with experience

in domestic international taxation who are looking

to better understand the role of tax treaties. The

course is further suitable for those who have previous

experience with tax treaties and wish to acquire a

more thorough understanding.

Courses available

CourseAccreditation

See page 22

IBFD, Your Portal to Cross-Border Tax Expertise

15

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Online Tax Courses

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Residence (English, Chinese) ••

Residence is a fundamental concept in tax treaties,

and there is more than first meets the eye. This

course explores the topic in detail to give you the

confidence of understanding all the treaty issues and

the implications of determining the treaty residence of

taxpayers.

Permanent Establishments (English,

Chinese) ••

This course provides an in-depth analysis of the

concept of permanent establishment in the context

of tax treaties. Participants should be familiar with the

structure of tax treaties and their allocation rules in

addition to the domestic law of at least one country, in

particular as it relates to cross-border situations.

Employment and Related Income (English) ••

This course introduces the tax treaty rules applicable to

employment and related income and further examines the

more complex concepts. Participants should be familiar

with the principles of tax treaties in addition to the domestic

law of at least one country, in particular as it relates to the

taxation of cross-border income of individuals.

Passive Income (English) ••

This course introduces the tax treaty rules that may

be applicable to cross-border passive income such as

income from immovable property, dividends, interest,

royalties, capital gains and technical services fees.

Participants should be familiar with the principles of

tax treaties in addition to the domestic law of at least

one country, in particular as it relates to the taxation of

cross-border income.

Business Profits (English) ••

This course introduces the tax treaty rules applicable to

business profits. Participants should have knowledge

of the principles of tax treaties in addition to the

domestic law of at least one country, in particular as

it relates to the taxation of cross-border income, and

should be familiar with the permanent establishment

concept as the course takes them from the basic ideas

through to the more complex concepts.

NEW! Double Taxation Relief (English) •

Although the basic concepts of double tax relief are

simple, many people starting their career in international

tax law fail to understand the extraordinary complexities

of double tax relief and the practical difficulties that

can severely reduce the effectiveness of the relief

granted by states. This course addresses the need for

a structured approach to studying this topic. It starts

by recapping on the fundamental concepts and then

introduces the many different issues raised by double

tax relief, gradually building up a detailed picture of the

complexities and practical problems.

Indirect Taxation

Fundamentals of Value Added Tax (English) •

This course introduces the basics of value added

taxes. As such, no great understanding of VAT is

required as the course will build from the absolute

basics through to some of the more complex

issues, such as exemption and internationally traded

services. The course looks at both the EU system

of VAT and some of the developments in states that

have adopted value added taxes in more recent

times.

Corporate Taxation

International Tax Planning (English) •

This course introduces the basics of international

tax planning and outlines the importance of tax

treaty and transfer pricing issues associated with

international tax planning. The course is suitable for

practitioners in tax advisory firms, tax specialists in

commerce and industry and government officials

who may have less familiarity with international

tax planning techniques and want to deepen their

knowledge in this field.

Transfer Pricing

Fundamentals of Transfer Pricing (English) •

The course covers the principles of transfer pricing,

which is one of the most important tax issues

currently faced by multinational enterprises and tax

administrations. The course provides an overview of

the legal framework for transfer pricing and the role

of tax treaties; introduces the OECD transfer pricing

guidelines; and provides practical explanation of

the arm’s length principle, comparability, transfer

pricing methods and related aspects such as

documentation and dispute avoidance and resolution

mechanisms.

• Introductory

•• Intermediate

••• Advanced

IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Online Tax Courses • Features

16

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.

Self-study

Self-study directs you to

supplementary reading materials.

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.

While completing self-study

assignments, you will encounter a

series of thought-provoking questions

to reflect upon.

Audio-visual lessons

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 wish to review.

Structure of online courses

Each course comprises sequentially

displayed core lessons. Following

their order will guide you through the

course in an organized and

logical way.

Additional optional lessons

(highlighted in light blue) cover

specialized topics to expand your

knowledge in the subject areas.

Features

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.

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Self Study

© 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 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, Your Portal to Cross-Border Tax Expertise IBFD International Online Tax Courses • Features

17

In addition, revision quizzes

will test your comprehension

of the course material

and help you identify your

strengths and weaknesses

so that you can go back and

relearn material if necessary.

Register online at

www.ibfd.org/training

Case studies

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

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

Quizzes incorporated in the lessons will help

you test your understanding of the concepts

and apply them in different scenarios.

Expert comments

Expert comments give access to short video

interviews and discussions with experts in the

field, providing insights into broader issues

related to the subject.

IBFD, Your Portal to Cross-Border Tax Expertise IBFD Tailored Tax Courses

18

For more information contact us

at [email protected]

The key to successful tailored training is ensuring that your training objectives will be achieved. From the first point of contact and throughout the development process, the Tailored Tax Courses department works in close partnership with your organization to ensure that a challenging course is made that accurately reflects and addresses your needs.

IBFD Tailored Tax Courses

Key learning objectives are agreed in advance

and are attained by means of interactive lectures,

group exercises and case work. All tailored training

courses are evaluated by the course participants,

and a summary is provided to the client organization

after the completion of the course.

Participants in tailored tax courses have the

advantage of learning from the best in the field,

and organizations have the advantage of raising

their level of competency in a cost-efficient way.

If you would like to discuss the opportunities for

your organization’s individual training, contact us at

[email protected] or +31-20-554 0160.

Benefits

X Tailored solutions: Tailor-made training for

your staff on specific topics at the level that

works best for the participants: introductory,

intermediate or advanced. Course dates are

scheduled at your convenience at the location of

your choice

X Expertise: Learning solutions delivered by

experienced tax professionals who are also

skilled instructors

X Up to date: Current tax developments that are

relevant to your work

X Complete: Comprehensive learning solutions,

presentations, interactive case studies,

printed materials and access to a tailored

online documentation platform with additional

resources including articles, case law and legal

documentation.

X Cost effective: Registration fee per participant

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Integrated learning solutions

Our tailored learning solutions can be combined with

online learning.

X Convenient: Learn the basic concepts online at

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X Focus: Combined with online learning solutions,

live classroom sessions can have stronger focus

on exploring practical application and more

complex issues

IBFD, Your Portal to Cross-Border Tax Expertise IBFD Tailored Tax Courses

19

For more information contact us

at [email protected]

Tailored Tax Courses topics

IBFD provides tailored tax courses, which are prepared in close collaboration with the

client. This menu provides an overview of the topics offered in the areas of tax treaties,

corporate taxation, transfer pricing, EU tax law and indirect tax, which can be combined

depending on your needs.

Tax Treaties

Corporate

Introductory

X Introduction to tax treaties

X Application of tax treaties

Introductory or Intermediate

X Residence

X Permanent establishment -

concept


X Investment and real state

income

X Payments for technology

X Treaty characterization issues

X Non-discrimination

X Triangular cases

X Partnerships and hybrid entities

X Anti-avoidance provisions and

treaty abuse

X E-Commerce issues

Advanced Workshops

X Permanent establishments


X Residence and dual residence

X Partnerships

X Triangular cases

X Recent case law on tax treaties

Individuals (with focus on expatriates)


X Residence

X Employment income

X Pensions

X Private capital (passive income

received by individuals)

X Emigration/immigration issues

X Employees’ stock options

X Taxation of high net worth

individuals

Corporate Taxation


X Introduction to international tax

planning

X Treaty aspects of international

tax planning

X Transfer pricing aspects of

international tax planning

X OECD Action Plan on Base

Erosion and Profit Shifting

X Tax structuring through debt

and other financing activities

X Tax structuring through

hybrid entities

X Tax planning for holding

activities

X Tax planning for intangibles

X Substantive tax planning –

business restructuring

X Substance requirements in

tax planning

X Hybrid financial instruments

X Derivatives

X Anti-avoidance rules

X Oil and gas taxation

Advanced Workshops

X International tax planning

X Hybrid financial instruments

X Derivatives

Transfer Pricing

Introductory

X OECD Transfer Pricing

Guidelines for Multinational

Enterprises

X Article 9 of the OECD MTC

X Transfer pricing methods

X Comparability

X Documentation

X Administrative aspects

X Latest developments

Intermediate

X Transfer pricing and business

restructuring

X Intangibles

X Intra-group services

X Cost contribution

arrangements

X Intra-group financing

X Indirect taxes and transfer

pricing

X Transfer pricing for

branches and permanent

establishments

X Transfer pricing risk

management

X Transfer pricing aspects of

international tax planning

Indirect Tax

Introductory

X Introduction to European

value added tax

X Special schemes

X Taxable amounts, tax rates

and exemption

X Deductibility of input VAT

X Imports and exports

X Intra-Community trade

Intermediate

X Current issues in the field of

VAT

X Place of supply of services

(new rules from 2010)

X Financial services

X Immovable property

X E-commerce

X Transfer pricing and VAT

EC Tax Law


X EU Direct Tax Directives

(Parent-Subsidiary Directive,

Interest and Royalties

Directive, Merger Directive)

X EU fundamental freedoms and

non-discrimination principles

X ECJ case law on corporate

taxation

X The role of EU law in

corporate tax planning

IBFD, Your Portal to Cross-Border Tax Expertise IBFD Training Locations Worldwide

20

“Thank you for the course which

is going to be of great help and

support in launching our careers

with the Revenue Department of

the Government of India.”

Sumitha Paramata,

Indian Revenue Service

To see all courses available

go to www.ibfd.org/training/

course-locations

In addition to the courses offered in Amsterdam, courses can be attended at our other locations around the world.

IBFD Training Locations Worldwide

Amsterdam, The Netherlands

IBFD’s head office in Amsterdam, The Netherlands, is

home to IBFD International Tax Training. Every year,

over 25 courses covering all areas of international tax

are scheduled in Amsterdam.

Kuala Lumpur, Malaysia

IBFD’s Asian office in Malaysia has trained tax

professionals in the region since 2007.

To see all courses available in Kuala Lumpur

go to www.ibfd.org/courses

Johannesburg, South Africa

As the business capital of South Africa,

Johannesburg has become a major international

business centre.

Singapore

Having offered tax courses in Singapore for over

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courses in one of the most vibrant, international

business centres in South East Asia.

IBFD, Your Portal to Cross-Border Tax Expertise IBFD Training Locations Worldwide

21

Christ Church, Barbados

Logically renowned for its particular tax regime,

Barbados is more than just a beautiful Caribbean

island. It is a dynamic, economic centre that hosts a

wealth of international businesses.

Dubai, UAE

Easy to reach, vibrant and cosmopolitan, Dubai has

become a major international business centre.

Moscow, Russia

Known as the city of opportunities, Moscow is

drawing increasing attention from investors, artists

and travellers alike.

São Paulo, Brazil

Third biggest of the BRICS countries, Brazil is a major

economic driver of Latin America and of the Southern

Hemisphere as a whole.

Shanghai, China

Being the fastest growing economy and host to

several multinational corporations, China is an ideal

course location for IBFD.

For more information, contact us at [email protected]

IBFD, Your Portal to Cross-Border Tax Expertise IBFD Course Accreditation

22

This list is not exhaustive. Many

IBFD tax courses may qualify

for CPE credits pursuant to the

rules of a number of professional

associations other than those

listed here. Participants are

encouraged to check with their

professional and/or national

associations to determine eligibility

in this respect. Course participants

should follow the guidelines of

their respective accrediting bodies

on the reporting of CPE credits.

Barbados

X ICAB: The Institute of Chartered

Accountants of Barbados.

Registered as an approved course provider.

Tax courses are eligible for CPE credits

Belgium

X IAB: Instituut van de Accountants en de

Belasting-consulenten/Institut des Experts-

comptables et des Conseils fiscaux (IAB-IEC

Recognition nr. B0181/2010-09 and

E0006/2013-06).


Tax courses and a selection of online

courses are eligible for CPE credits

Ireland

X ITI: Irish Taxation Institute.

Tax and online courses are eligible for

CPE credits

Singapore

X SIATP: Singapore Institute of Accredited Tax

Professionals

Tax and online courses are eligible for

CPE credits

The Netherlands

X CEDEO

IBFD International Tax Courses are CEDEO

recognized accountancy courses

X RB: Register Belastingadviseurs/Registry of

Tax Advisers.Registered as an approved

course provider.

Tax and online courses are eligible for CPE

credits

X NBA: Nederlandse Beroepsorganisatie van

Accountants.


Online courses are eligible for CPE credits

United Kingdom

X CIOT: The UK Chartered Institute of Taxation.

Registered as a recognized course provider. Tax

and online courses are eligible for CPE credits

X ATT: The Association of Taxation Technicians.

Registered as an approved course provider. Tax

and online courses are eligible for CPE credits

United States

X NASBA: The National Association of State

Boards of Accountancy of the US. (IBFD

is registered with NASBA as a sponsor of

continuing professional education on the

National Registry of CPE Sponsors.)

Tax courses are eligible for CPE credits

IBFD International Tax Courses are endorsed by many professional accrediting bodies. Courses qualify for Continuing Professional Education (CPE) credits with several organizations including those listed below.

IBFDCourse Accreditation

For more information, please visit www.ibfd.org/training or contact us: [email protected]

www.ibfd.orgIBFD, Your Portal to Cross-Border Tax ExpertiseIBFD, Your Portal to Cross-Border Tax Expertise

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