Topics Covered
- Introduction to international taxation
- Residence
- Basic rule permanent establishments
- Other types of permanent establishments
- Cross-border business activities
- Attribution of profits to permanent establishments
- Dividends, interest, royalties and fees for technical services
- Anti-abuse provisions on dividends, interest, royalties and fees for technical services
- Capital gains
- Double tax relief
- Principal purpose test
Learning Objectives
Skills practiced and developed during the course include:
- Interpret and apply the tax treaty provisions relating to the various types of income of enterprises
- Correctly interpret tax treaty terms
- Identify the treaty residence of an enterprise including tiebreaker rules
- Determine whether a non-resident enterprise has a permanent establishment in a state
- Attribute income and expenses to a permanent establishment
- Determine the amount of withholding tax due on cross-border dividends, interest and royalty payments
- Apply the beneficial ownership concept
- Allocate taxing rights regarding different types of capital gains
- Determine the amount of double tax relief
- Correctly apply the Principal Purpose Test
Read this sample case study to understand more about the type of topics and skills you will learn during this online course.
Who Should Participate
The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry, government officials who regularly encounter issues related to cross-border taxation and anyone who desires to develop a comprehensive understanding of international taxation principles.
Recommended prerequisites (for guidance only) and advance preparation
Participants should have a basic knowledge of the domestic tax system of at least one country, specifically, taxation of foreign income derived by resident companies and domestic-source income received by non-resident companies. In addition, a basic understanding of the function of double tax treaties would be helpful, but the course will presume that course participants are new to dealing with tax treaties.
No advance preparation is necessary. All required study material is provided within the online training
Total Study Time and Access Period
Continuing Professional Education (CPE)
We recommend you check with your respective accrediting organizations to determine the eligibility of CPE credits.
International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
Recommended NASBA CPE credits for this course is: 22
FAQ
See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or contact us at info@ibfd.org.
Additional Information
Field of study: Taxes
Delivery format: Online - QAS Self Study
Disclaimer
Please note that the content of this online course is subject to change based on updates in industry standards, regulatory requirements, and other developments. We strive to provide the most accurate and current information; however, we recommend verifying any critical details independently.