IBFD International Tax Training 2015

Transcription

1 IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Training 2015 International Tax Courses / Tailored Tax Courses / International Online Tax Courses

2 Courses at a Glance IBFD International Tax Courses & IBFD International Online Tax Courses TRP Choose from a range of introductory, Tax Research intermediate and advanced-level Research Fellow courses. Tax Course Platform Program Euro sign IBFD International Tax Courses Tax Treaties Gouvernment Summer Online Course: Course Principles of International Consultancy and Comparative Taxation Principles of International Taxation International Taxation of Oil and Gas and Other Mining IBFD member Activities (My account) Mobile Tax Facts International Tax Aspects of Permanent Establishments International Taxation of E-Commerce Tax Treaties - Selected Issues and Case Studies Tailored Tax Courses How we work Individual Taxation International Taxation of Expatriates TAX Authors and Tax Research Correspondants Corporate NEW Taxation Principles New of International (general) Tax Planning Dollar sign International Tax Aspects of Corporate Tax Planning TEXT Tax Planning and Substance NEW International Tax Structuring for Multinational New Collection Text document Enterprises Tax Planning Workshop Base Erosion and Profit Shifting Selected Issues International Taxation of Oil and Gas and Global Events Article Other Mining Activities US Corporate Taxation International Taxation of Banks and Financial Institutions International IBFD Taxation Member of E-Commerce Laptop International Tax Aspects of Mergers, Acquisitions and Corporate Finance $ See for details on course date and location. RSS feed Transfer Pricing Principles of Transfer Pricing Taxation of Supply Chain Restructuring Transfer Tax Pricing Eventsand Indirect Taxes Transfer Calendar Pricing and Intra-Group Financing Print book Transfer Pricing and Intangibles E-book Transfer Pricing and Attribution of Profits to Permanent Establishments Transfer Pricing Risk Management: Online Shop Online book Implementation and Monitoring Description & IBFD Staff fdfdfdasd Indirect Taxation Introduction to European Value Added Tax European Value Added Tax Selected Issues E-book Description & European collection Value Added Tax Workshop fdfdfdasd Taxation of Supply Chain Restructuring International Tax Aspects of Permanent Establishments Transfer Pricing Print book and Indirect Taxes Description & collection fdfdfdasd VAT Considerations in M&A Transactions Introductory Intermediate Advanced IBFD International Online Tax Courses Online Tax Treaties Collections Tools Fundamentals of Tax Treaties (English, Chinese, Spanish) Residence (English, Chinese) Permanent Establishments (English, Chinese) Journals Contact Employment and Related Income (English) Passive Income (English) Business Profits (English) NEW! Double Taxation Relief (English) Online book Indirect Taxation collection Fundamentals of Value Added Tax (English) Corporate Taxation International Tax Planning (English) Books Description & fdfdfdasd Description & fdfdfdasd Transfer Pricing Fundamentals of Transfer Pricing (English) 2

3 Table of Contents 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 Tailored Tax Courses 3

4 IBFD International Tax Training Courses designed to meet your professional needs 4

5 IBFD International Tax Training 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. 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. 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 International Tax Training is our preferred course provider because it offers an extensive range of highly technical quality courses. Ernst & Young, Brazil Course locations Amsterdam The Netherlands Moscow Russia Christ Church Barbados Kuala Lumpur Malaysia Sao Paulo Brazil Johannesburg South Africa Dubai UAE Singapore 5

6 IBFD International Tax Courses IBFD International Tax Courses 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. 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. Knowledge: In-depth understanding of critical principles and concepts in just a few days Interactive learning: Participation in group discussions and case studies Course credits: Certificates for CPE/CPD accreditation purposes Supplementary study material: Additional learning with comprehensive printed/online documentation and resources Networking: Meet and discuss current tax issues with international instructors and participants Topics that matter Our international tax courses cover a wide range of topics in international taxation. 6

7 IBFD, Your Portal to Cross-Border Tax Expertise IBFD International Tax Courses How To Register How To Register Tax Courses Enrolment applications for international tax courses are available via 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 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 and taxcourses@ibfd.org or visit For enquiries about registrations, contact IBFD Customer Support at info@ibfd.org or 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 7

8 IBFD International Tax Courses Tax Treaties and Individual Taxation Early Bird Discount See page 12 Tax Treaties and Individual Taxation Our Tax Treaties and Individual Taxation courses are designed for: Tax advisers Accountants and tax lawyers In-house tax managers International tax executives Tax directors 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. Interpretation and application of international tax treaties Treatment of cross-border income under tax treaties Principles of transfer pricing VAT EU tax law An overview of basic tax planning structures 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. Interpretation and application of international tax treaties Treatment of cross-border income under tax treaties Principles of transfer pricing An overview of basic tax planning structures The application of anti-avoidance provisions International Tax Aspects of Permanent Establishments 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. The concept of permanent establishments Attribution of profits to permanent establishments Permanent establishments and EU VAT aspects Non-discrimination and triangular cases 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. Tax treaty characterization of e-commerce transactions Entitlement to tax the income from e-commerce transactions Entitlement to levy VAT on e-commerce transactions Recent developments with respect to the taxation of the digital economy Corporate Taxation Our Corporate Taxation courses are designed for: Tax practitioners In-house tax managers Tax directors Accountants International tax executives Government officials and tax inspectors 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. Key concepts in international tax planning Hybrid and derivative financial instruments 8

9 IBFD International Tax Courses Corporate Taxation See for details on course dates and location. Tax structures involving the use of holding and finance companies, branches, tax consolidation and hybrid entities Supply chain structuring 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. Supply chain structuring Tax planning for treasury operations 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. Tax residence and substance Substance in trust companies Substance and permanent establishments Transfer pricing and substance Beneficial ownership and limitation on benefit clauses EU and OECD aspects of substance R&D activities and intangibles 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. X X Treaty aspects of international tax planning Holding and financing activities E-commerce activities Transfer pricing aspects of international tax planning intangibles Supply chain structuring 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. Treasury tax planning and BEPS Domestic and treaty anti-avoidance rules Hybrid mismatches E-commerce Intangibles Introductory Intermediate Advanced 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. Tax planning opportunities and risks regarding acquisition activities Holding and financing activities Post-acquisition structuring of manufacturing and selling activities International Taxation of Oil and Gas and Other Mining Activities This course is designed to provide participants with in-depth analyses of international taxation issues related to oil and gas and other mining activities. International tax considerations in the oil and gas industry Permanent establishments Offshore exploration activities Treaty characterization of income in the oil and gas industry Expatriate employees in the oil and gas industry Transfer pricing issues 9

10 IBFD International Tax Courses Transfer Pricing See for details on course dates and location. Course Accreditation See page 22 US Corporate Taxation Learn the foundations of the US international tax system quickly. Whether your work relates to USbased multinationals or multinationals with activities in the United States, this course will help you understand its complex international tax system. Terms and concepts in US tax systems Taxation of foreign corporations Double taxation relief Foreign activities of US corporations 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. Specific issues involving bank branches Withholding taxes Derivatives and structured financial products Financial transaction taxes FATCA 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. X X Tax principles in M&A deals Tax due diligence EU law Acquisition tax planning Tax-efficient financing of M&A deals Transfer Pricing Our Transfer Pricing courses are designed for: Lawyers Accountants In-house transfer pricing managers Transfer pricing advisers International tax executives Tax directors Government officials and tax inspectors 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. Transfer pricing methodologies Business restructuring OECD/UN Guidelines Documentation requirements Transfer pricing risk management Dispute resolution Different types of intercompany transactions Intellectual property 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. Tax-effective supply chain transformation OECD Transfer Pricing Guidelines Restructuring of intangibles PEs Indirect taxes This course is a must in particular for: 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. 10

11 IBFD International Tax Courses VAT / Indirect Taxation 88% of our course participants say that the course met their expectations. Introductory Intermediate Advanced Intercompany loans Guarantees Cash pooling 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. Definition of intangibles CCAs Innovation regimes in Europe Characterization issues and valuation This unique, top-level course on transfer pricing and intangibles is a must in particular for: Corporate tax and intellectual property legal counsel 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. Identifying a PE Attribution of profits to PEs Pricing of intra-entity dealings Business restructurings E-commerce 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. Tax accounting Audits Transfer pricing control framework Transfer pricing dispute resolution 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 Distribution Manufacturing R&D Services Intra-group financing Intellectual property Indirect taxes VAT / Indirect Taxation Our Indirect Taxation courses are designed for: Tax practitioners In-house tax managers Tax directors VAT consultants Accountants and tax lawyers International tax executives Government officials and tax inspectors 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. Taxable persons Goods and services Place and time of supply Taxable amount VAT rates Exemptions Deduction of input tax Immovable property Imports and exports Administrative obligations Intra-Community trade 11

12 IBFD International Tax Courses VAT / Indirect Taxation 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. Recent developments and current issues in the field of VAT Intra-Community (triangular) supplies of goods Cross-border services Consignment stock and warehousing arrangements 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. 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. General tax principles of M&A transactions VAT issues for seller, acquirer and target Target and acquirer meetings 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. Immovable property transactions Online supplies of digital goods and services Financial services Manufacturing and selling activities of multinational enterprises This course covers the following specific issues: VAT issues in the specific areas of financial services and real estate A discussion of the VAT systems in the Middle East and North Africa including a comparison with the European VAT Directives where relevant Section focusing on the VAT implications of crossborder supplies and anti-avoidance and fraud issues See for details on course dates and location. 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 12

13 Transfer Pricing Study Guide Transfer Pricing Study Guide 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. Online Study Guide Features 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. All study material is available online and allows for easy printing. The structure follows the syllabus of the CIOT ADIT examination 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. Register online at 13

14 IBFD International Online Tax Courses IBFD International Online Tax Courses 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. 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 Interactive learning environment including audio-visual lessons, self-study assignments and quizzes Courses that can be adapted to your schedule and pace. All courses available in English; selected courses in Spanish and Chinese A way to achieve your learning objectives without the time out of the office and cost of travel Certificates for CPE/CPD accreditation purposes Case studies to put theory into practice and apply the concepts to real-life scenarios Enterprise packages to train entire organizations and departments at a lower cost Course Accreditation See page 22 Online Course benefits Quality: Expand your knowledge using the broad range of high-quality content developed by top tax experts from around the world Control: Focus on less familiar concepts and skim over well-known materials 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 Motivation: The courses challenge you with highly interactive multimedia lessons and provide immediate responses and feedback, motivating you to learn more Affordability: Save valuable time and money for you and your organization Courses available 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. 14

15 IBFD International Online Tax Courses 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. 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. Introductory Intermediate Advanced 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 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. 15

16 IBFD International Online Tax Courses Features Features Self Study 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 is written for states that mainly use the exemption method, and Art. 23B is written for states that mainly use the credit method. Articles 23A and 23B of the OECD Model Source: IBFD Tax Treaties Database Click here Copyright 2009 IBFD International Tax Academy This document is protected by copyright of IBFD or its licensors. Only registered course participants are granted 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 is available on the site. Click here for full Copyright Notice. 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. ITA101 Fundamentals of Tax Treaties - Lesson 2b (11:30/26:49) Outline Thumbnails Narration How tax treaties operate Lesson overview Search Royalties taxation under domestic law Royalties treaty allocation of taxing rights Allocating taxing rights under the treaty Royalties treaty allocation of taxing rights Royalties treaty allocation of taxing rights Interest taxation under domestic law Interest treaty allocation of taxing rights Interest treaty allocation of taxing rights Interest treaty allocation of taxing rights Income from immovable property domestic Income from immovable property domestic Income from immovable property domestic Allocating taxing rights under the treaty Treaty allocation rules - comparison Categories of income in the OECD Model Treaty allocation rules Source state thresholds Source state thresholds Source state thresholds Source state thresholds Employment income threshold Business profit threshold Business profit threshold Permanent establishment Overview of the OECD Model Convention Allocating taxing rights under the treaty Residence State SLIDE 16 OF 32 PAUSED 00:04 / 01:22 Income from immovable property RENT Source State May tax May tax OECD OECD Model Tax Convention on Income and on Capital Art. 6 INCOME FROM IMMOVABLE PROPERTY (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 may be taxed in that other State IBFD International Tax Academy 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. 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. 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. 16

17 IBFD International Online Tax Courses Features Case studies Case studies help you put theory to practice and apply the concepts learned to reallife 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. 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. 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. Register online at 17

18 IBFD Tailored Tax Courses IBFD Tailored Tax Courses 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. 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 tailoredcourses@ibfd.org or Integrated learning solutions Our tailored learning solutions can be combined with online learning. Convenient: Learn the basic concepts online at your own pace Efficient: Participants study online in their own time before attending live classroom training to consolidate and advance their learning Focus: Combined with online learning solutions, live classroom sessions can have stronger focus on exploring practical application and more complex issues Benefits 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 Expertise: Learning solutions delivered by experienced tax professionals who are also skilled instructors Up to date: Current tax developments that are relevant to your work Complete: Comprehensive learning solutions, presentations, interactive case studies, printed materials and access to a tailored For more information contact us at tailoredcourses@ibfd.org online documentation platform with additional resources including articles, case law and legal documentation. Cost effective: Registration fee per participant is competitive. Your organization saves on travel and accommodation costs 18

19 IBFD Tailored Tax Courses 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. For more information contact us at Tax Treaties Corporate Introductory Introduction to tax treaties Application of tax treaties Introductory or Intermediate Residence Permanent establishment - concept Attribution of profits to PEs Investment and real state income Payments for technology Treaty characterization issues Non-discrimination Triangular cases Partnerships and hybrid entities Anti-avoidance provisions and treaty abuse E-Commerce issues Advanced Workshops Permanent establishments Attribution of profits to PEs Residence and dual residence Partnerships Triangular cases Recent case law on tax treaties Individuals (with focus on expatriates) Introductory or Intermediate Residence Employment income Pensions Private capital (passive income received by individuals) Emigration/immigration issues Employees stock options Taxation of high net worth individuals Corporate Taxation Introductory or Intermediate Introduction to international tax planning Treaty aspects of international tax planning Transfer pricing aspects of international tax planning OECD Action Plan on Base Erosion and Profit Shifting Tax structuring through debt and other financing activities Tax structuring through hybrid entities Tax planning for holding activities Tax planning for intangibles Substantive tax planning business restructuring Substance requirements in tax planning Hybrid financial instruments Derivatives Anti-avoidance rules Oil and gas taxation Advanced Workshops International tax planning Hybrid financial instruments Derivatives Transfer Pricing Introductory OECD Transfer Pricing Guidelines for Multinational Enterprises Article 9 of the OECD MTC Transfer pricing methods Comparability Documentation Administrative aspects Latest developments Intermediate Transfer pricing and business restructuring Intangibles Intra-group services Cost contribution arrangements Intra-group financing Indirect taxes and transfer pricing Transfer pricing for branches and permanent establishments Transfer pricing risk management Transfer pricing aspects of international tax planning Indirect Tax Introductory Introduction to European value added tax Special schemes Taxable amounts, tax rates and exemption Deductibility of input VAT Imports and exports Intra-Community trade Intermediate Current issues in the field of VAT Place of supply of services (new rules from 2010) Financial services Immovable property E-commerce Transfer pricing and VAT EC Tax Law Introductory or Intermediate EU Direct Tax Directives (Parent-Subsidiary Directive, Interest and Royalties Directive, Merger Directive) EU fundamental freedoms and non-discrimination principles ECJ case law on corporate taxation The role of EU law in corporate tax planning 19

20 IBFD Training Locations Worldwide IBFD Training Locations Worldwide In addition to the courses offered in Amsterdam, courses can be attended at our other locations around the world. Amsterdam, The Netherlands To see all courses available go to course-locations 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 To see all courses available in Kuala Lumpur go to Johannesburg, South Africa 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 As the business capital of South Africa, Johannesburg has become a major international business centre. Singapore Having offered tax courses in Singapore for over 7 years, IBFD is delighted to continue hosting its courses in one of the most vibrant, international business centres in South East Asia. 20

21 IBFD Training Locations Worldwide 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 tailoredcourses@ibfd.org 21

22 IBFD Course Accreditation IBFD Course Accreditation 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. 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 ICAB: The Institute of Chartered Accountants of Barbados. Registered as an approved course provider. Tax courses are eligible for CPE credits Belgium IAB: Instituut van de Accountants en de Belasting-consulenten/Institut des Expertscomptables et des Conseils fiscaux (IAB-IEC Recognition nr. B0181/ and E0006/ ). Registered as an approved course provider. Tax courses and a selection of online courses are eligible for CPE credits Ireland ITI: Irish Taxation Institute. Tax and online courses are eligible for CPE credits Singapore SIATP: Singapore Institute of Accredited Tax Professionals Tax and online courses are eligible for CPE credits The Netherlands CEDEO IBFD International Tax Courses are CEDEO recognized accountancy courses RB: Register Belastingadviseurs/Registry of Tax Advisers.Registered as an approved course provider. Tax and online courses are eligible for CPE credits NBA: Nederlandse Beroepsorganisatie van Accountants. Registered as an approved course provider. Online courses are eligible for CPE credits United Kingdom CIOT: The UK Chartered Institute of Taxation. Registered as a recognized course provider. Tax and online courses are eligible for CPE credits ATT: The Association of Taxation Technicians. Registered as an approved course provider. Tax and online courses are eligible for CPE credits United States 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 For more information, please visit or contact us: taxcourses@ibfd.org 22

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24 IBFD, Your Portal to Cross-Border Tax Expertise Contact IBFD IBFD Head Office Rietlandpark DW Amsterdam P.O. Box HE Amsterdam, The Netherlands Tel.: (GMT+1) IBFD Office for Asia and the Pacific Suite 22.03, Level 22, Centrepoint South No. 1 The Boulevard, Mid Valley City Lingkaran Syed Putra Kuala Lumpur, Malaysia Tel.: (GMT+8) Fax: ibfdasia@ibfd.org International Tax Courses Tel.: Fax: taxcourses@ibfd.org International Online Tax Courses Tel.: Fax: onlinecourses@ibfd.org Tailored Tax Courses Tel.: Fax: tailoredcourses@ibfd.org Free services IBFD offers a wide range of free services on international taxation to keep you informed on subjects of your interest. Sign up today at Social media Follow IBFD on LinkedIn: Join our group Friends of IBFD: link.ibfd.org/friends_of_ibfd Follow us on Visit us at