Double Tax Treaties in Corporate International Tax Planning

Speaker:  Allan Cinnamon  |  CPD Hours: 6.0

Price £545 plus VAT

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OBJECTIVES

Tax treaties are a dynamic area of the international tax field. The most recent development on 7 June 2017 was the signing by 68 countries of The Multilateral Instrument (‘MLI’). It heralds a radical step change, facilitating the speedier way by which double tax treaties may be rapidly amended in order to comply with the BEPS project. Tax practitioners need to become thoroughly familiar with the MLI, as well as other crucial aspects of double tax treaties.

Illustrated with numerous practical examples, this course will cover pertinent cases, government actions and trends across the world that interpret and apply tax treaties to business operations.

The course will be based on an analysis of the relevant articles of the OECD Model Treaty in relation to the crucial role they play in international tax planning for UK companies expanding and operating abroad; and for foreign companies doing business and investing into the UK. The treaty analysis will provide the building blocks for the application of treaties to the practical structuring of international operations, illustrated by considering specific treaties. The overarching impact of BEPS on double tax treaties will be fully covered.

CONTENT

  • Treaty residence and dual residence
  • Permanent Establishments and the BEPS proposals
  • The Digital Economy and BEPS
  • Dividends, Interest and Royalties
  • Capital Gains
  • Double Tax Relief
  • Using the Non-Discrimination article
  • Treaty shopping anti-avoidance and the BEPS measures
  • The overall impact of BEPS, the MLI and the EU Tax Avoidance Directive
  • Recent treaty cases

WHO SHOULD ATTEND

This course is suitable for those with some experience of the role of tax treaties in international tax planning, as well as those who want a basic but in depth understanding of how the model OECD treaty operates in practice.

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