FULL - TIME Master MASTER IN INTERNATIONAL TAXATION

FULL - TIME Master MASTER IN INTERNATIONAL TAXATION

The main purpose for the foundation of ISDE was to complete the education of law, economics & business graduates, with the aim to contribute to society training lawyers, economics and business managers, with an excellent education and capable to respond with professionalism and integrity to the demands required by these professions in their different specialties. ISDE has grown and developed, as well as its offer in Master Programs and its commitment on preparing lawyers, economics and business managers, who will assume important responsibilities in the present society. Message from the Chancellor of ISDE Mr. José Juan Pintó Ruiz

Board of Governors 3 SENIOR MANAGEMENT TEAM Mr. Jorge Pinto Sala President Mr. Juan Jose Sanchez Puig Executive Director Mr. Manuel Garayo de Orbe Secretary of the Senior Management Team. Public prosecutor Mr. Rafael Abadia Jordana Member of the Senior Management Team. Lawyer Mr. Vicente Sierra Rocafort Member of the Senior Management Team. Lawyer Mr. Jorge Pinto Sala President Mr. Juan Jose Sanchez Puig Executive Director

Governing Bodies 4 ACADEMIC BOARD Mr Pablo Paisán Ruiz Lawyer at Cuatrecasas Gonçalves Pereira Professor Alegría Borrás, PhD Professor of Private International Law Mr Gianpaolo Monteneri President, Monteneri Sports Mr David Jiménez Mouriz Tax Consultant/Lawyer Mr Javier Hervás Partner at KPMG Sports Advisory Mr David Jiménez Mouriz Partner. Dutilh Tax Department Mr David Pérez García Director of Tax and Estate Planning at Popular Banca Privada, Grupo Banco Popular Mr Efraim Barak Senior Partner, D. Mirkin & Co. Advocates and Notaries Ms Marta Iglesias Doctor of Law. Professor of International Law, Complutense University of Madrid Mr Emilio Ramírez Lawyer. Director and owner of Ramírez y Asociados. Mr José Luis Pérez Benítez Partner-Consultant, Pérez & Partners Consultants Mr Ramón Terol Professor of Administrative Law. Secretary of the Electoral Guarantees Board, the Higher Sports Council. Member of the Sports Lawyers Association. Ms Diane Stephenson Solicitor in England and Wales. Lawyer. Mr Javier Rodríguez Ten Phd. in Law. Member of the Board of Directors of the Spanish Sports Law Association. Ms Anabel Campo Blanco Master in Human Resources. Secretarial Manager of Cuatrecasas, Gonçalves Pereira. Mr Patricia Vidal Martínez Counsel, Uría Menéndez, Madrid office Mr Plácido Molina Barrister. Director of Collection, Cuatrecasas Gonçalves Pereira FullTime Master

Letter from the Director of ISDE Mr. Juan José Sánchez Puig The ver y etymology of the word Master embodies the philosophy underpinning ISDE s educational objective, where the student is the focal point and the absolute protagonist. All of our resources and effor ts are focused on achieving this objective, which is to ensure that the student has mastered the subject matter by the end of the programme. Par tnerships with the leading figures in the world of law and business, a proven training method, the personal attention of the teaching and coordination team, and all of our technical and human resources are placed at the disposal of our students in our quest to ensure that the programmes achieve their utmost educational goals and make the time and effor t devoted to them wor th the while. Throughout the years, we have striven and succeeded in ensuring that our students not only acquire the most upto-date knowledge, but that they also accomplish their personal and professional development goals through the acquisition of skills and competencies that lay the foundation for a new stage in their careers. The sum of the effor ts of the ISDE and its students without whose commitment the most qualified staff or technical resources would serve no purpose- has made us proud to see how those who trusted us with their training needs have gone on to enjoy highly successful careers and to occupy the senior positions they so brilliantly and so efficiently prepared themselves for. Loyalty to the spirit and methods that have earned us the trust of thousands of students, and continuous upgrading and improvement of our training methods, have placed us at the forefront of our field, as evidenced by our performance in independent rankings. The accomplishment of these objectives in recent years has driven us to never lose sight of the fact that our goal is the success of our students. Mr. Juan José Sánchez Puig Executive Director

Introduction The Universidad Carlos III de Madrid aims to contribute to the improvement of society with quality teaching and advanced research accordingly to international standards. This not only gives special relevance to the degree programs but also the graduate programs. Meanwhile ISDE is an educational institution that since its inception has been concerned to provide legal training at the highest level, both in Spain and abroad. Among his extensive and consolidated academic offerings - distributed in Masters Full Time, Executive and specialized courses either in person or online - have always enjoyed a special prestige those programs to train front-line professionals in the field of law. Both institutions have decided to jointly create the "Master in International Taxation", with the intention of responding to the need to create well-known professionals in this field.

Objectives 7 Objectives The Master aims to provide an integrated view of the problems, formulas and solutions offered by the international taxation, both in Europe and in North America. Student s Profile Professionals or newly graduated students, who wish to project their activity in the field of taxation, with the aim of providing a complete and systematic knowledge in taxation essentially from a practical perspective. These professionals and students may come from different areas, such as Law, Business Administration, Economics, etc., and of various nationalities. Number of Students 30 students maximum.

Faculty 8 UC3M FACULTY PARTNER UNIVERSITIES FACULTY COMPANY AND LAW FIRM FACULTY Juan José Zornoza Pérez Hugo López Lçopez (Universidad Pública de Navarra) Miguel Cruz Amorós (PWC) Federico Linares García de Cosio (Ernst & Young) Enrique Ortiz Calle Alfredo García Prats (Universidad de Valencia) Carlos Concha Carballido (PWC) Carolina del Campo (KPMG) Maria Luisa González-Cuéllar María Teresa Soler Roch (Universidad de Alicante) Javier González Carcedo (PWC) Carlos Marín (KPMG) Andrés Báez Moreno José Manuel Almudí Cid (Universidad Complutense) Isabel López-Bustamente (Deloitte) José Antonio Tortosa (KPMG) Violeta Ruiz Almendral Alejandro García Heredia (Universidad de Cádiz) Jesús López Tello (Uría) Victoria von Richetti Cirujea (Pérez Llorca) Aitor Navarro Ibarrola Santiago Ibáñez (Universidad de Valencia) Félix Vega Borrego (UAM) Domingo Jiménez-Valladolid (UAM) Yariv Brauner (Universidad de Florida Gainsville) Luis Eduardo Schoueri (Universidad de Sao Paulo) Felipe Yáñez (Universidad de los Andes) Camilo Zarama (Universidad Externado de Colombia) Mauricio Marín Elizalde (Universidad Externado de Colombia) Miguel Cremades Schulz (Uría) Victor Viana Barral (Uría) Joan Hortalà (Cuatrecasas) Florentino Carreño (Cuatrecasas) Andrés Sánchez (Cuatrecasas) Manuela Martín (Cuatrecasas) Andrés Sánchez (Cuatrecasas) Carmen de Pascual (Cuatrecasas) Marta Moreno de Alborán Gómez-Pablos (Pérez Llorca) Javier Prieto Ruiz (Araoz y Rueda) Javier Hernández-Galante (Ashurst) Néstor Carmona (AEAT) Felipe Rubio Cuadrado (AEAT) Gerardo Pérez Rodilla (AEAT) Silvia López Ribas (AEAT) Joao Felix Nogueira (Intenational Bureau of Fiscal Documentation) Alejandro Calderón UNAM *ISDE and UC3M reserves itself the capacity to set the last-minute changes it deems appropriate, as well as contents, timing, schedule of classes, activities and faculty of the program, in order to ensure at all times, the quality and best use of academic contents by the Master students. *ISDE y UC3M reserva la capacidad de realizar los cambios de última hora que estime convenientes, así como el contenido, el calendario, el horario de clases, actividades y profesores del programa, a fin de garantizar en todo momento, la calidad y el mejor uso de contenidos académicos de los estudiantes de Máster. Master Full Time

Academic Programme 9 MASTER IN INTERNATIONAL TAXATION (PROGRAM CONTENTS) I. Fundamentals on international taxation Worldwide taxation and source taxation. Juridical and Economical Double Taxation. Double Taxation Conventions and Domestic Relief of International Taxation. Double Taxation and Domestic Law. II. Taxation of Non Residents in Spain The concept of residence in the Spanish tax law The taxable event of IRNR Taxation with and without permanent establishment in TRLIRNR III. Double Taxation Conventions. 1. The basics of DTCs: source taxation, resident taxation, and correction of double taxation. 2. The DTC Models (OECD/UN/US Model). Fundamental of International Tax Policy) 3. Subjective Scope Persons Covered Residence and double residence. 4. Taxes covered. 5. Allocation rules. The concept of Permanent Establishment Immovable Property Business profits Shipping and air transport. Dividends. Interests. Royalties. Capital gains. Income from employment. Director s fees. Artistes and Sportsmen. Pensions. Goverment service. Students. Other Income. Capital. 6. Methods for the elimination of Double Taxation. The method article in DTC s Domestic relief of double taxation (The Spanish Foreign Tax Credit, Participation Exemption and Exemption for Foreign PE). 7. Non-discrimination. 8. Administrative Issues Mutual agreement procedure. Exchange of Information. Assistance in the collection of taxes. 9. Transversal issues related to DTC s Arm s length principle and transfer pricing Interpretation of DTC s Tax treaty abuse. Domestic SAAR s for Spanish resident tax payers (CFC rules, Tax Havens rules, Interest deduction barriers, Holding companies rules). IV. Inheritance Tax Treaties.

Academic Programme 10 V. European Tax Law. 1. Basic principles of European Tax Law (positive and negative integration). 3. Negative integration. Fundamental Freedoms State Aids. Book-Tax conformity and accounting harmonization. 2. Positive integration. The Customs Union Value Added Tax Excise Duties Capital Duties Direct Taxes Parent Subsidiary Directive Interest and Royalty Directive Fiscal Merger Directive Savings Directive The CCCTB Project Proceedings Directive on administrative cooperation in the field of taxation. Directive on on mutual assistance for recovery Arbitration Convention ISDE and UC3M reserves itself the capacity to set the last-minute changes it deems appropriate, as well as contents, timing, schedule of classes, activities and faculty of the program, in order to ensure at all times, the quality and best use of academic contents by the Master students.

Moreover, the students will also attend lectures for two weeks at the University of Florida, USA, in order to learn U.S. tax matters (MCUSA, FATCA, etc.) It is expected to create an award of excellence for the top three students in order to take an internship of four months in collaborating entities of the Master, specialized in international taxation. The top four students will form a team in the European Tax Moot Court (Louvain). Methodology ISDE has created a practical and an effective system, after several years working, based on learning through real cases and using the same methodology as a real lawyer. That is the reason why the education is provided both in the academic headquarters and in the law firms. Thus what it is learned is the application of the law, the detection of legal problems, the legal reasoning and the appropriate draft claims. Nevertheless this is only the first phase of the master, since in the second one the students have an internship in different prestigious law firms and national or international legal consultancies. ISDE believes that the legal practice is not based on fictitious problems, but on real cases. This is why we have the best professionals: lawyers, lecturers, and economists, who make up a perfect team and understand each other perfectly. This combined method aims at providing students with a work method which will allow them to face any kind of legal problem in future. This specific program in International Taxation LLM is completed by different common subjects that are essential for a lawyer and paying special attention to the international relations and foreign trade. In the second phase each student completes this phase at the premises of one of the collaborating entities of the master, under the conditions and rules set by those entities. For this reason, the schedule for the second phase is subject to further modifications. The total duration of the program exceeds 1.500 hours. CLASSES At ISDE Madrid Campus. SECOND PHASE Program Schedule The first phase takes place at our academic headquarters. The method is based on a combination of study of cases and case study. During this period, the student attends lectures in Madrid. The study of cases gives students a general approach to the different subjects of the program. At the same time this particular method develops students agility for legal reasoning. On the other hand, the case study consists in analyzing, deeply and precisely, those particular aspects which are especially relevant in international legal practice. From the month of September, students will be incorporated to various Spanish foreign firms for tax advice during an academic semester. They will be guided by a tutor who will be responsible for introducing them to the day to day operations of the Firm / Company and all tax matters in which the student will participate. The placement of the student will be determined by the Academic Department, based on their language skills, their academic results and the preferences expressed by the host office or firm. This will guarantee the success of a good internship and student orientation.

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Admissions Procedure 14 Documentation Applicants willing to participate in the Admission Process of the Master shall complete a Registration Form, and send it, fully completed, along with the following documentation: Curriculum vitae Copy of the University Degree Copy of the University transcripts or University results certificate (in case you have not finished your studies at the moment of application, please send us your current academic record) A minimum of one reference letter from someone who knows you from an academic or a working background Copy of the passport or other relevant identification document These documents can be directly sent by email or by post, to the attention of the Admissions Department, to: 6 Recoletos St. 28001 Madrid, Spain masters@isdemasters.com Applying Those applicants, who successfully meet the minimum entry requirements to join the course, shall also take the following tests on a later date: Motivation test Psychometric test Juridical skills exam English level exam The number of the places available to study the Master is limited and applications will be dealt in strict order of inscription. We recommend a prompt application to the program. Location and Timetable The first phase of the Master in International Taxation takes place in our Academic Headquarters in Madrid. The students are obliged to attend lectures everyday plus the additional classes that can take place during also the afternoons. The students shall take practical cases and exams related to the classes they have each week. Furthermore, the students will visit once a week different departments of the top law firms in Spain and other institutions and companies. These legal offices and institutions are partners to ISDE. The second phase takes place in the law Firms, institutions or companies that have collaborated in teaching the program in the first phase. ISDE collaborates and works closely with institutions in the following countries: Spain, Portugal, France, Italy, UK, Switzerland, Norway, Sweden, Belgium, Germany, Austria, Netherlands, Poland, Canada, USA, Argentina, Chile, Brazil, Panama, Peru, Mexico, Costa Rica, etc. The critera used to appoint the institution that will receive the student consists in a detailed case by case analysis of the academic performance of the student, personal profile, and the previous acceptance from the receiving institution of that particular student. Prospective students are able to submit applications all year round. However, the Admissions Committee assesses the received applications twice a month and Applicants are informed immediately of the outcome of their application. At the same time, if necessary, applicants can be asked to submit further information or documentation to clarify certain aspects of their academic and/or professional background. The Admissions Committee is also entitled to subject the acceptance of a certain applicant to a personal interview.

Contact Details The Admissions Procedure will be directly deal with ISDE s Admissions Department 6 Recoletos St, 28001 Madrid Phone.: +34 911 265 180 Fax: +34 915 762 021 E-mail: masters@isdemasters.com www.isdemasters.com Full TimeMaster