IBFD International Tax Academy

IBFD International Tax Academy ITA Open ITA In - house ITA Online 2011 / 2012 Register online at www.ibfd.org/courses IBFD, Your Portal to Cross-Border Tax Expertise

International Tax Academy International Tax Academy The International Tax Academy (ITA) was established by IBFD in 1989, and is recognized worldwide as a reputable learning centre in the field of international taxation. ITA s 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 ITA Open, ITA In-house and ITA Online gives participants both 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 ITA trains over 1,300 participants each year from advisory, multinational, government and other organizations around the world. ITA offers a range of training solutions designed to meet the various needs of customers. ITA Open ITA In-house ITA Online Choose from a range of introductory, intermediate and advanced-level courses Acquire a thorough understanding of principles and concepts in just a few days Participate in group discussions and case studies Network with international instructors and participants Supplement learning with extensive printed/online documentation/resources Obtain certificates for CPE/CPD purposes Access to complementary resources through the ITA Documentation Platform Train larger groups in a convenient and cost-effective way Courses arranged at your premises or an international location of your choice Choose from ITA s extensive range of courses Customize/combine courses to meet your learning requirements Access to online platform with complementary documentation Obtain certificates for CPE/CPD purposes Participate in group discussions and case studies Meet your learning objectives without the time and cost of travel Choose specific courses to study, then determine your own schedule and pace Benefit from an interactive learning environment including audio-visual lessons, self-study assignments, quizzes and further reading Obtain certificates for CPE/CPD purposes Enterprise packages available to train organizations/departments at lower cost NEW Integrated Courses ITA combines open and in-house courses with online courses for comprehensive, effective and cost-efficient training. For details regarding ITA courses, including a full course programme, details of instructors, dates and venues, please visit www.ibfd.org or contact us at itacourses@ibfd.org. 2

ITA Open Courses 2011 / 2012 Courses offered by ITA Choose from a range of introductory, intermediate and advanced-level courses: Tax Treaties Introductory Interpretation and Application of Tax Treaties Principles of International Taxation International Taxation of Expatriates Summer Course Principles of International and Comparative Taxation Intermediate International Tax Aspects of Permanent Establishments Tax Treaties Negotiations Workshop Practical Application of Tax Treaties Recent Developments in International Taxation NEW International Taxation of Oil and Gas and Other Mining Activities Advanced Tax Treaty Workshop Permanent Establishments Workshop Recent Case Law on Tax Treaties Introductory Indian Corporate Taxation Intermediate NEW Practical Aspects of EU Direct Corporate Taxation Practical Aspects of International Tax Planning Taxation of Holding Companies in Europe International Tax Planning for Multinational Enterprises Debt and Financial Restructuring NEW Tax Risk Management NEW International Tax Aspects of Private Equity and Venture Capital Corporate Taxation NEW International Tax Aspects of Mergers, Acquisitions and Corporate Finance Advanced NEW Innovative Financial Products Transfer Pricing Introductory Introduction to Transfer Pricing Intermediate Principles of Transfer Pricing Transfer Pricing: Intangibles and Intra-Group Finance NEW Transfer Pricing and PE Profit Attribution Transfer Pricing Aspects of Business Restructuring Indirect Taxation Introductory Introduction to European Value Added Tax Intermediate European Value Added Tax Selected Issues Advanced European Value Added Tax Workshop Advanced NEW Transfer Pricing Workshop 3

ITA Open Courses 2011 / 2012 ITA Courses Please note our Early Bird Discount offer on page 9. TAX TREATIES Interpretation and Application of Tax Treaties Introductory Level This course covers a wide range of tax issues that have to be addressed in interpreting and applying tax treaties, such as the concept of treaty residence and permanent establishment, attribution of profits to a permanent establishment, passive income, employment income, double taxation relief methods and non-discrimination principles. The course will provide participants with a framework for understanding the issues as well as opportunities to apply the knowledge acquired during the course in case studies. International Taxation of Expatriates Introductory Level This course is designed to give the participants a thorough understanding of the tax implications associated with individuals who move across international borders. The course examines the possible consequences of emigration under domestic law, the relevant provisions of the OECD Model Convention on Income and on Capital, and the interaction between domestic law and the OECD Model. Specific topics that may be relevant to expatriates, such as the tax treatment of employee stock options, pension income and exit taxes are also covered. Summer Course Principles of International and Comparative Taxation Introductory Level This course is designed to provide participants with the basic concepts and principles of international tax law. It examines the sources of international tax law, how those sources of law fit together, and the current issues of international tax law. The concepts and principles of international tax law are further applied to the practice of business structures and planning. The course includes many case study sessions to ensure that the concepts discussed within the course are well understood from a practical perspective. Principles of International Taxation Introductory Level This course is designed to provide participants with the essentials of international taxation. The first three days are dedicated to the fundamental concepts relevant to the interpretation and application of international tax treaties. This introduction provides participants with the conceptual tools to fully grasp issues discussed on Day 4 and Day 5. Day 4 deals with the principles of transfer pricing and how these principles apply to intra-group services. Day 5 provides an overview of basic tax planning structures and an insight into the application of the most common antiavoidance provisions. International Tax Aspects of Permanent Establishments Intermediate Level This course is designed to provide participants with an in-depth analysis of the concept of permanent establishment (PE). Practical issues, such as VAT and profit allocation, will be covered. This will be combined with the use of case studies to ensure that participants leave the course with the confidence to apply what they have learned. Emphasis will be placed on a number of complex tax issues relating to PEs, such as non-discrimination, e-commerce, triangular cases and the problems surrounding agency PEs. The latest OECD developments and PE issues that can arise from business restructuring will also be examined. Tax Treaties Negotiations Workshop Intermediate Level Giving you the confidence to successfully negotiate tax treaties is the principal objective of this workshop. We will discuss various provisions that can be included in tax treaties based on the OECD and UN Models and the implications of these on the scope and application of tax treaties, the distributive rules for different categories of income, elimination of double taxation and special administrative rules. These discussions will be put into practice in a treaty negotiation workshop. 4

ITA Open Courses 2011 / 2012 Practical Application of Tax Treaties Intermediate Level This course deals with the application of double tax treaties in complex scenarios and with the issues that can arise in those circumstances. The course covers the application of the dual resident tiebreaker rules, the application and classification issues involving royalty and other cross-border passive income, the application of the PE concept and the attribution of PE profits, triangular cases, entity taxation and treaty anti-abuse rules. Recent Developments in International Taxation Intermediate Level This 3-day intermediate to advanced-level course provides participants who deal with double tax treaties on a regular basis with an update on the recent developments in the application and interpretation of tax treaties. NEW International Taxation of Oil and Gas and Other Mining Activities Intermediate Level This course provides participants with an in-depth analysis of the international tax issues related to oil and gas and other mining activities. More specifically, it covers how these activities are dealt with under tax treaties and how tax treaties impact the taxation of enterprises engaged in such activities and their employees. Tax Treaty Workshop Advanced Level This workshop provides participants with an in-depth understanding of the treaty rules and methodologies for permanent establishments and triangular cases. Participants will be guided through a series of complex case studies aimed at highlighting the problems concerning permanent establishments, attribution of PE profits and triangular cases. NEW Recent Case Law on Tax Treaties Advanced Level This 3-day advanced-level course provides participants who deal with double tax treaties on a regular basis with an in-depth understanding of the important international developments including recent OECD updates and case law, and how these developments impact the application of double tax treaties. TRANSFER PRICING Introduction to Transfer Pricing Introductory Level Transfer pricing is one of the most important international tax issues faced by multinational enterprises and tax administrations today. This 2-day course introduces participants to the fundamental principles of transfer pricing, the transfer pricing methodologies, and the application of these principles and methodologies. The course focuses on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The delivery of the formal sessions is complemented by interactive case studies and practical examples. Principles of Transfer Pricing Intermediate Level It is often said that transfer pricing is not an exact science, hence to develop an understanding of transfer pricing principles and methodologies, consideration of their practical application is considered paramount. This 4-day course introduces participants to transfer pricing principles and methodologies and the application of these principles and methodologies to specific categories of intra-group dealing. These sessions are complemented by practical sessions that cover the application of the principles and methodologies. The focus of this practically orientated course is on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the issues that can arise in the application of these requirements. 5

ITA Open Courses 2011 / 2012 Transfer Pricing: Intangibles and Intra-Group Finance Intermediate Level Intra-group finance and intangible property dealings raise a range of complex transfer pricing considerations, which, if not adequately addressed, may result in significant risk exposure for a multinational. This 3-day course explores the application of transfer pricing principles to intangible property and to intra-group financing arrangements. The course covers the identification and classification of intangible property, royalty rate determination, cost sharing/contribution arrangements and an introduction to intangible property valuation techniques. Intra-group finance is covered by firstly discussing the importance of transfer pricing in relation to such dealings, and then considering the practical application of transfer pricing methodologies to intra-group loans, guarantee fees and cash pooling arrangements and the practical approaches to managing the transfer pricing aspects of intra-group financing transactions. The delivery of the formal sessions is complemented by practical examples, and the course concludes with an interactive case study to consolidate participant learning. NEW Transfer Pricing and PE Profit Attribution Intermediate Level Integrated Course This integrated course combines cutting edge online instruction (ITA Online) with 2½ days of interactive classroom training, exposing participants to the issues involved in the identification of a PE and attribution of profits thereto. By considering the application of the OECD Transfer Pricing Guidelines by analogy, this course provides participants with the tools to practically determine the profits of a PE. The content of the course is combined with practical examples and case studies, and sessions considering the issues surrounding PE in a business restructuring context. Transfer Pricing Aspects of Business Restructuring Intermediate Level This 3-day course is designed to provide participants with a thorough knowledge of the transfer pricing issues that would need to be taken into account when a business restructuring takes place within an MNE. Participants will acquire an in-depth understanding of the trends relating to business restructurings, the relevant tax and transfer pricing concepts and methodologies, and how an in-house tax manager of MNEs might approach the reorganization of supply chain operations. Moreover, the course will address the tax laws of China and India with regard to the provisions applicable to business restructurings. NEW Transfer Pricing Workshop Advanced Level This 2-day workshop explores the transfer pricing issues arising for a multinational group that operates in a number of jurisdictions around the globe. The workshop, which includes a rolling case study, considers the transfer pricing issues relating to the distribution, manufacturing, R&D, financing and management operations of the multinational group. These sessions are complemented by sessions on dispute avoidance and resolution in the context of the case study. 6

ITA Open Courses 2011 / 2012 CORPORATE TAXATION Taxation of Holding Companies in Europe Intermediate Level This course provides an overview of the tax planning goals and objectives of a multinational group and an in-depth discussion of the use of EU holding companies and their role in financing and intellectual property structures. The course addresses the tax aspects to be taken into account when establishing holding companies in Europe, sets forth the criteria to be used in evaluating and selecting a holding company location, and offers an overview of the domestic legislation of countries that are often used as a location to establish holding companies within Europe. NEW Tax Risk Management Intermediate Level This course is designed to provide participants with an in-depth analysis of the tax issues related to tax risk management. In response to a number of widely known corporate failures, the tax risks call for the effective management of such risks. Companies in different industries and in different regions of the world administer the process of managing tax risks in a wide variety of ways. The course provides an in-depth analysis of the legislation rules and the approach of both tax authorities and governance bodies with respect to tax risk management. NEW International Tax Aspects of Private Equity and Venture Capital Intermediate Level This course provides participants with an in-depth analysis of the legal and tax issues related to private equity and venture capital. More specifically, it describes the legal and tax aspects that have to be taken into account in making investment decisions and it gives a detailed overview of the structures and techniques used in daily practice. International Tax Planning for Multinational Enterprises Intermediate Level This course provides participants with a practical understanding of international tax planning tools for multinational enterprises. In particular, the course will cover tax planning techniques and trends for their holding, financing, manufacturing, R&D and selling activities. The course will conclude with discussions of the relevant domestic and tax treaty anti-avoidance rules. NEW International Tax Aspects of Mergers, Acquisitions and Corporate Finance Intermediate Level This course is designed to provide participants with an in-depth analysis of the tax consequences arising from cross-border M&A and corporate financing transactions. The course covers the full scope of M&A, focusing on various techniques that should be in place in order to successfully take over a business. The most common structures used to efficiently finance an M&A deal from a tax perspective will be presented too. Further, an in-depth analysis of the tax issues arising from the implementation of the most common cross-border corporate financing techniques will be provided. Debt and Financial Restructuring Intermediate Level This course provides participants with an in-depth analysis of the legal and tax issues related to debt and financial restructuring in the context of the current financial crisis. More specifically, it describes the legal and tax aspects that have to be taken into account in making restructuring decisions and gives a detailed overview of the structures and techniques used in daily practice. 7

ITA Open Courses 2011 / 2012 Practical Aspects of International Tax Planning Intermediate Level This course is aimed at analysing the fundamentals of international tax planning in a structured and consistent manner. The course provides participants with an overview of basic corporate financing options such as debt financing, leasing, use of finance companies, branches and hybrid entities. In addition, the use of innovative financial instruments such as hybrids and derivatives for corporate financing purposes will be addressed with practical examples. Moreover, the course will illustrate how these building blocks may be put together to finance cross-border acquisitions and optimally structure holding activities. Then, the course will cover tax planning techniques and trends for manufacturing, R&D and selling activities of multinational enterprises. It will conclude with discussions of relevant domestic and tax treaty anti-avoidance rules. NEW Practical Aspects of EU Direct Corporate Taxation Intermediate Level This course is designed to give the participants a thorough understanding of the elements of EU law that are of practical importance with respect to the direct taxation of corporations. Course participants will gain an understanding of how to apply and use both the legislation and the case law of the EU in their daily tax advice and consultancy practice. Specific emphasis will be put on the Parent-Subsidiary Directive, the Interest and Royalties Directive and the Merger Directive, which have a great impact on the tax planning of European companies. In addition, this course offers the opportunity to examine the leading cases of the European Court of Justice and the latest developments with practitioners who are renowned in the field of EU law. NEW Innovative Financial Products Advanced Level This course is designed to provide participants with in-depth analyses of the regulatory, accounting and tax issues arising from the use of hybrids, derivatives and other innovative financial products such as repos and securities lending transactions. Participants will acquire structured background knowledge of the concepts and principles of these innovative products and their role in cross-border corporate financing and tax planning techniques. ITA is our preferred course provider because it offers an extensive range of highly technical quality courses. Ernst & Young, Brazil attending several ITA courses confirmed IBFD s well-founded reputation. FedEx Express, EMEA 8

ITA Open Courses 2011 / 2012 INDIRECT TAXATION Introduction to European Value Added Tax Introductory Level This course is designed to provide participants with a framework of the most important VAT principles and issues which anyone dealing with value added tax in the European Union is confronted with and needs to understand. The course will end each day with a case study to enable participants to gain confidence in applying the skills acquired during the course. European Value Added Tax Selected Issues Intermediate Level This course focuses on complex issues that can arise for international businesses in the application of value added tax in the European Union. The course will cover intra-community (triangular) supplies of goods and services, consignment stock and warehousing arrangements, and VAT planning and control. European Value Added Tax Workshop Advanced Level This interactive workshop consists mainly of case studies and is designed for participants who are experienced with the principles of value added tax in the European Union and who want to train themselves further on important issues of particular complexity or interest for VAT practice in internationally operating businesses and industry. Early Bird Discount A 30% discount* will be applied for registrations received 60 days or more before the commencement of ITA 2011 courses in Amsterdam and Barbados. For courses in Kuala Lumpur and Singapore, a 20% discount* will be applied for registrations received 30 days or more before the commencement of the course. *non-cumulative with membership or any other discount I found the ITA trial course on Residence very valuable in that the course focuses on the relevant aspects of residence from a local and international perspective, and it provides the student with a range of very useful training options, e.g. an audiovisual presentation, professional articles on the topic for the student s review, and quizzes. Christian Wiesener, Tax Advisor, South Africa We have identified ITA as a course provider with an international reputation and orientation that proves to be a centre for knowledge-sharing among professionals. Throughout the years we have found that ITA offers highly valued courses with regard to technical contents and we have received an excellent feedback on the high level of professionalism and care for our delegates. Pirola Pennuto Zei & Associati, Italy 9

ITA Online 2011 ITA Online Courses ITA Online, an integral part of IBFD s International Tax Academy, is proud to be your source of the highest quality, interactive online training solutions. Excellence is our top priority, and we accomplish it by carefully crafting our courses in collaboration with international tax experts combining their theoretical and practical experiences. Benefits of ITA Online Quality Enjoy the broad spectrum of content developed by top tax experts from around the world. Put theory to practice with relevant examples and case studies. Convenience Access a course 24/7 from anywhere in the world. No need for extra software. Flexibility Control Stimulation Affordability Attend the course at the time and place most convenient to you. Retake the course or return to the last-visited section. Set your own schedule and study pace. Focus on less familiar concepts and skim over wellknown materials. Keep engaged with our highly interactive multimedia, which will give you immediate response and the feedback you need. Train your organizations, departments or individuals and save time and money on travel and books. Access to diverse and relevant materials will help you master the subject areas. 10

ITA Online 2011 Structure of ITA Online courses International Tax Academy Online Courses > ITA101 Fundamentals of Tax Treaties ITA Online, Your portal to International Tax Training ITA101 Fundamentals of Tax Treaties This Site Each course comprises sequentially displayed core lessons. Following their order, you will be guided through the course in an organized and logical fashion. Additional optional lessons (highlighted in light blue) cover specialized topics to expand your knowledge in the subject areas. 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. Welcome International Tax Academy ONLINE Lessons (1) The international tax environment - Domestic law as the foundation of international tax - Features with cross-border impact - Overview of international tax environment - Introduction to key concepts Core study time: 55 min Audio Lesson Lesson 1: Audio Lesson (A handout is available for you to print and make notes while following the audio lesson. Click here for the handout.) Play audio lesson Study time: 30 min Glossary Revise key terms Revise key terms covered in this lesson. For each term you can look up a definition in the IBFD International Tax Glossary. Click here Study time: 20 min Handout Conceptual map of factors influencing the international tax environment View/print a conceptual map of the international tax environment, consisting of three levels. Click here Expert Comment Interview with Michael Lennard (Part 1) This is the first part of an interview between Joanna Wheeler and Michael Lennard where he talks about international organizations active in the area of international tax law and their aims in this respect. Click here Study time: 5 min (1) The international tax enviroment (2a) Double taxation relief (2b) How tax treaties operate (3) Revision quiz 1 (4) Role and development of model treaties (5a) The making of tax (5b)Eligibility to treaty treaties benefits (6) Revision quiz 2 (7b) Interpretation and (7a) Case studies dispute resolution (8a) Policy considerations (8b) Expert comment ITA Online course features 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 want to review. ITA101 Fundamentals of Tax Treaties - Lesson 2b (11:30/26:49) Outline Thumbnails How tax treaties operate Lesson overview Narration 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 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. 2009 IBFD International Tax Academy SLIDE 16 OF 32 PAUSED 00:04 / 01:22 Self-study directs you to supplementary reading materials to further develop your understanding of the course topics. 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. In the course of the self-study process, you will encounter a series of thought-provoking questions to reflect on. 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. 11

ITA Online 2011 Case studies help you put theory to practice and apply the learned concepts to real-life scenarios. Hands-on exercises will challenge you to answer various questions and subsequently provide feedback on your performance. 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 on the topic. Quizzes incorporated in the lessons will help you test your understanding of the concepts and apply them in different scenarios. In addition, revision quizzes will test your mastery of the course material and help you identify your strengths and weaknesses so that you can go back and re-learn material if necessary. 12

ITA Online 2011 Expert comments give access to short video interviews and discussions with experts in the field, providing insights into broader issues related to the subject. Additional documentation At the start of each course you will have access to written instructions on how to proceed with the course. For additional guidance consult our frequently asked questions (FAQ) section. An electronic binder of course materials including presentation handouts, articles and further reading may be downloaded for your future reference after the course completion. Currently available Online courses ITA101 Fundamentals of Tax Treaties ITA102 Residence ITA103 Permanent Establishments ITA104 Employment and Related Income ITA105 Passive Income ITA106 Business Profits How to order, sign up for a free trial lesson, or get more information All courses are available in English. A selection is also available in Chinese or Spanish. For more details on each course, please visit our website at www.ibfd.org. To sign up for a free trial lesson, or to place your order, visit www.ibfd.org/courses. Continuing professional education ITA Online courses are accredited with various professional organizations and allow you to fulfil your CPE requirements. For more information, contact itacourses@ibfd.org. Pricing IBFD Members Single-course registration 5-course subscription (or more) 20% discount on standard price 499 / $ 674 standard price 30% discount on standard price For larger orders, an enterprise deal can be arranged. Please contact ITA Sales at itasales@ibfd.org or call +31-20-554 0319 for more information. For more information on ITA Online, please visit our website at www.ibfd.org. 13

ITA In-House 2011 / 2012 ITA In-house The International Tax Academy offers tailored in-house training, which can be held at your premises or at a suitable location of your choice. You can select from the ITA Open courses, or request a tailored course designed to meet the level and knowledge requirements of the participants, and the particular topics of interest to your organization. ITA In-house clients, including many governments and leading advisory and multinational firms from around the world, have benefited from: Cost-efficient fees structure Flexibility and convenience Experienced instructors and tailored training programmes Choice of delivery methods Extensive documentation and resources Professional/CPE accreditation You will find examples of topics ITA In-house can cover on the next page. NEW Integrated Solutions In-house ITA also provides integrated training solutions, whereby online courses are combined with live classroom training. Many benefits can be realized by combining these different methods of training: Foundation concepts can be studied online at the participants own pace Having completed the online course, participants enter the classroom with the same level of understanding of key concepts ensuring maximum benefit is derived from the live training Classroom sessions can focus on reinforcing and building on key concepts, exploring practical application and more complex issues A comprehensive and cost-effective way to train groups Example #1: Introduction to International Tax Treaties (Introductory/Intermediate level) Online course: Fundamentals of Tax Treaties (approximately 8 weeks of self-study), followed by In-house training: Application of International Tax Treaties (2 days of classroom training) Example #2: Permanent Establishments (Intermediate/Advanced level) Online course: Permanent Establishments (approximately 8 weeks of self-study), followed by In-house training: Permanent Establishments Workshop (2 days of classroom training): For more information, please visit www.ibfd.org/courses, or contact us at ita@ibfd.org or tel. +31 20 5540160 14

ITA In-House 2011 / 2012 Examples of ITA In-house topics include: Tax Treaties Corporate Taxation Corporate Introductory Introduction to tax treaties Tax treaty interpretation Introductory or Intermediate Residence Permanent establishment concept Attribution of profits to PEs Investment and real estate income Payments for technology Treaty characterization issues Non-discrimination Triangular cases Partnerships and hybrid entities Anti-avoidance provisions and treaty abuse Individuals (with focus on expatriates) Introductory or Intermediate Residence Employment income Pensions Private capital (passive income received by individuals) Emigration/immigration issues Employee stock options Introductory or Intermediate Introduction to tax planning Tax structuring through debt and other financing activities Tax structuring through branches and tax consolidation Tax structuring through hybrid entities Tax planning for holding activities Tax planning for intangibles Substantive tax planning business restructuring Hybrid financial instruments Derivatives Anti-avoidance rules Advanced Workshops Hybrid financial instruments Derivatives Advanced Workshops Permanent establishments Attribution of profits to PEs Residence and dual residence Partnerships Triangular cases Treaty case law 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 finance European VAT 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 Introductory EU Direct Tax Directives (Parent-Subsidiary Directive, Interest and Royalties Directive, Merger Directive) EU fundamental freedoms and non-discrimination principles EU Tax Law ECJ case law on corporate taxation 15

International Tax Academy International Tax Academy closer to you Next to the courses run in the IBFD head office in Amsterdam, ITA Open offers courses in the following locations. Singapore, Singapore Kuala Lumpur, Malaysia Beijing, China Christ Church, Barbados Please refer to our course calendar, pages 17-18 to find a suitable course in your location of choice, or visit www.ibfd.org/courses for the latest agenda. 16

ITA Open Calendar 2011 / 2012 Price (Euro) Price (Dollar) (Prices are exclusive of VAT) European Value Added Tax Workshop Advanced Level 15 16 September 2011 Amsterdam 1,520 1,900 Principles of Transfer Pricing Intermediate Level 26 30 September 2011 Kuala Lumpur 1,650 Principles of Transfer Pricing Introductory Level 5 7 October 2011 Barbados 1,200 1,500 Transfer Pricing and PE Profit Attribution Intermediate Level 12 14 October 2011 Amsterdam 1,900 2,375 International Taxation of Oil and Gas and Other Mining Activities Intermediate Level 17 20 October 2011 Amsterdam 2,015 2,519 Practical Aspects of International Tax Planning Intermediate Level 24 28 October 2011 Amsterdam 2,350 2,938 Principles of International Taxation Introductory Level 31 October 4 November 2011 Kuala Lumpur 1,650 NEW Recent Case Law on Tax Treaties Advanced Level 7 9 November 2011 Amsterdam 1,850 2,313 European Value Added Tax Selected Issues Intermediate Level 21 22 November 2011 Amsterdam 1,520 1,900 Transfer Pricing Workshop Advanced Level 23 24 November 2011 Amsterdam 1,520 1,900 Tax Treaty Workshop Advanced Level 28 30 November 2011 Amsterdam 1,850 2,313 Principles of International Taxation Introductory Level 5 9 December 2011 Amsterdam 2,520 3,150 Tax Risk Management Intermediate Level 23 24 December 2011 Amsterdam 1,596 1,995 Recent Developments in International Taxation Intermediate Level 11 13 January 2012 Barbados 1,200 1,500 Course dates may be subject to change. Please refer to the IBFD website (www.ibfd.org) for updated information. 17

ITA Open Calendar 2011 / 2012 Price (Euro) Price (Dollar) (Prices are exclusive of VAT) Tax Treaties Negotiations Workshop Intermediate Level 23 26 January 2012 Amsterdam 2,289 2,861 Interpretation and Application of Tax Treaties Introductory Level 27 29 February 2012 Amsterdam 1,943 2,428 International Tax Aspects of Permanent Establishments Intermediate Level 12 15 March 2012 Amsterdam 2,289 2,861 US Corporate Taxation Introductory Level 19 20 March 2012 Amsterdam 1,596 1,995 Introduction to European Valued Added Tax Introductory Level 26 29 March 2012 Amsterdam 2,289 2,861 Transfer Pricing: Intangibles and Intra-Group Finance Intermediate Level 2 4 April 2012 Amsterdam 1,943 2,428 Recent Case Law on Tax Treaties Advanced Level 16 18 April 2012 Amsterdam 1,943 2,428 Tax Risk Management Intermediate Level 23 24 April 2012 Amsterdam 1,596 1,995 International Tax Aspects of Mergers, Acquisitions and Corporate Finance Intermediate Level 7 9 May 2012 Amsterdam 1,943 2,428 Practical Aspects of International Tax Planning Intermediate Level 21 25 May 2012 Kuala Lumpur 1,800 International Taxation of Expatriates Introductory Level 23 25 May 2012 Amsterdam 1,764 2,205 Course dates may be subject to change. Please refer to the IBFD website (www.ibfd.org) for updated information. 18

Registration Form I would like to register for the course: Title:... Location:... Course dates:... Your details Method of payment O Mr O Ms O Cash O Invoice Credit Card Name:... First name:... Job title:... Organization:... Address:... City and postal code:... Country:... Telephone:... O VISA O Eurocard/Mastercard American Express Card no.: Expiry date (mm-yyyy): Card validation code: Cardholder s name: Cardholder s signature: Email:... Signature: Date:... Bank transfer upon receipt of an invoice Date:... O I have a full IBFD Membership (20%) O Membership number:... O I am entitled to a special discount O Discount code/details:... Contact person responsible for training within your organization O Mr O Ms Name:... Function:... Telephone:... Email:... If the invoice address differs from the above, please indicate: Organization:... Attention of:... Address:... City and postal code:... Country:... Your reference / PO#:... By signing the registration form you agree with the terms and conditions and the cancellation policy of the IBFD International Tax Academy, as laid down on our website. Please return the completed form to the IBFD International Tax Academy, fax: +31-20-620 9397. Email: itacourses@ibfd.org Clients in Asia, the Americas, the Caribbean, Australia and New Zealand will be invoiced in US$ ITA sends a free quarterly newsletter to its clients containing information about courses. Please tick the box if you do not wish to receive this.

Contact IBFD International Tax Academy International Tax Academy IBFD Head Office P.O. Box 20237 1000 HE Amsterdam The Netherlands Tel.: +31-20-554 0160 Fax: +31-20-620 9397 Email: itacourses@ibfd.org Website: www.ibfd.org ITA Asia-Pacific IBFD Asia Sdn Bhd, Suite 22.03, Level 22, Centrepoint South No.1, the Boulevard, Mid Valley City Lingkaran Syed Putra 59200 Kuala Lumpur Malaysia ITA Online Tel.: +31-20-554 0181 Fax: +31-20-620 9397 Email: itaonline@ibfd.org Arcotia Hatsidimitris (Head of ITA) Tel.: +31-20-554 0180 Email: a.hatsidimitris@ibfd.org Tel.: +6-03-2287 0709 Fax: +6-03-2287 0729 Email: ibfdasia@ibfd.org The world s leading provider of international tax training solutions IBFD, Your Portal to Cross-Border Tax Expertise ITA August 2011