Tax Treaty Aspects of Corporate International Tax Structuring

Download programme
Tax treaties play an important role in the international tax structuring of multinational groups. This course examines the interplay between domestic tax law and tax treaties on cross-border business activities, the role of tax treaties in mitigating double taxation, in facilitating international tax structuring opportunities and in mitigating outcomes of tax structures which are considered to be too aggressive. The course also addresses eligibility to tax treaty benefits in view of recent developments. Tax treaty interpretation issues and disputes that are associated with the use of tax treaties in such corporate tax structuring practices are also addressed. These issues are explained with illustrative examples and interactive questions.

Topics Covered

  • Applying tax treaties to cross-border business activities
  • The role of tax treaties in international tax structuring
  • Eligibility to treaty benefits
  • Interpretation and dispute resolution

Learning Objectives

After completing this course, you will be able to:

  • Define the role and impact of domestic tax laws and tax treaties in cross-border business activities
  • Assess the importance of tax treaties for double taxation avoidance and their potential role in the mitigation of single taxation
  • Identify international tax structuring opportunities under tax treaties
  • Apply the conditions for the application of tax treaties and eligibility to tax treaty benefits when they are applied in a different context 
  • Differentiate different treaty anti-abuse rules and their scope of application 
  • Identify sources of disputes under tax treaties and how issues of interpretation arise
  • Determine the processes of resolving disputes and mutual agreement procedures 

Who should participate

This course will benefit tax professionals working in multinational groups, tax and legal advisory firms and governments, including:

  • In-house tax professionals and advisers responsible for the structuring of corporate group entities and their associated tax affairs
  • Legal professionals assessing the risk of tax controversy associated with corporate tax structures
  • Government officials reviewing and auditing multinational groups and their corporate tax structuring practices 

Recommended prerequisites (for guidance only) and advance preparation

Participants in this course are expected to have at least 3 to 5 years of experience in international tax and are familiar with the key concepts of international tax law.

Total Study Time and Access Period

Access to the online course is granted for a period of 2 months, from the date of ordering or the indicated start date.

Mandatory course activities: 6 hours 39 min

All mandatory course activities can be completed within the access period by dedicating approx. 45 mins of study per week. Please note that study materials included in the course or certificate programme will be accessible for the duration of the access period only. Non-mandatory supplementary material is also provided in this course.

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: 7

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

Course last reviewed: February 2024

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.