This course explores international corporate taxation and will equip you to understand the complexities of international tax and adopt best practice approaches to transfer pricing.

The impact of cross-border transactions on revenue collection, and the design of effective tax systems, should be of key importance to tax policy makers and administrators. Structures and prices are not always set fairly, resulting in significant implications for the collection of taxes. At the same time, tax systems and administration can deter the inbound investment that can be critical for economic growth.

Week one focuses on the relationship of corporate taxation to investment, with particular attention to the role of international tax treaties. Week two focuses on mechanisms for collecting tax, with particular attention to the effect of transfer pricing rules that address pricing distortions in transactions within multinationals.

Course Objectives

On completion, you will be able to:

• Identify the key direct tax principles that underpin an effective framework for cross-border taxation
• Understand the OECD and UN Model Tax Conventions and develop the knowledge to approach tax treaty issues with confidence
• Explain how transfer pricing is legislated in local tax law and strategies
• Appreciate where mispricing and potential tax revenue leakage may occur
• Understand the tools and techniques undertaken by a tax administration to identify and mitigate against transfer pricing problems

Key Topics

• Principles of direct taxation and their implications in designing a cross-border tax framework
• Interaction of domestic tax laws and international tax treaties
• Features of model treaties (OECD and UN)
• Taxation of foreign income and gains
• Withholding taxes and double taxation relief
• Definition and occurrence of transfer pricing
• Adjustment of transfer prices and taxable profits
• Advanced Pricing Agreements (APAs)
• Negotiations through tax treaty competent authority
• Domestic tax avoidance and thin capitalisation rules

All courses will be conducted entirely in English. A proficient level of both spoken and written English is required by all delegates so that they are able to fully benefit from the course and participate in our interactive style of training.