Programme Format: 16 Hours · Weekend Delivery · Five Sessions
A practical international taxation course covering treaties, permanent establishments, withholding taxes, transfer pricing, BEPS, Pillar Two and cross-border structuring.
DAYS 1–2
MODULE 1 · 7 LEARNING HOURS
Module 1 · Day 1 · 3.5 Hours
Foundations, International Tax Law & Treaty Access
Foundations, Treaty Interpretation and Treaty Entitlement
- Foundations of International Taxation: Residence, source and citizenship concepts, juridical vs economic double taxation, tax neutrality, nexus and source rules.
- International Tax Law & Treaty Interpretation: OECD, UN and US Model frameworks, Vienna Convention principles, Commentaries, protocols, MFN clauses and treaty characterisation.
- Treaty Residence & Treaty Entitlement: Persons covered, taxes covered, liable-to-tax tests, dual residence, tie-breakers, place of effective management and treaty access.
- Practical Case Lab: Read a treaty from Article 1 onward and determine residence, treaty eligibility and allocation of taxing rights.
Session Outcome: Participants should be able to identify which treaty applies, who qualifies for treaty access and how treaty interpretation begins.
Module 1 · Day 2 · 3.5 Hours
Permanent Establishment, Business Profits & Profit Attribution
Cross-Border Nexus, Article 7 and PE Profit Attribution
- Permanent Establishment & Cross-Border Nexus: Fixed place, agency, construction and service PE concepts, exclusions, preparatory or auxiliary activities, remote working and digital presence.
- Business Profits under Article 7: Source-state taxing rights, interaction between Article 5 and Article 7, branch concepts and business profit allocation.
- PE Profit Attribution: Separate enterprise approach, functions-assets-risks analysis, branch dealings, expense allocation and attribution principles.
- PE Case Workshop: Assess PE exposure and profit attribution for a regional sales, service or remote-working model.
Session Outcome: Participants should be able to identify PE exposure and connect PE creation with the amount of profit potentially taxable in the source state.
DAYS 3–4
MODULE 2 · 7 LEARNING HOURS
Module 2 · Day 3 · 3.5 Hours
Cross-Border Income, Withholding, Financing & Double Tax Relief
Income Classification, Withholding Tax and Relief from Double Taxation
- Cross-Border Income & Withholding Taxes: Dividends, interest, royalties, technical services, capital gains, employment, directors fees, pensions and other income.
- Cross-Border Financing, Entities & Instruments: Debt vs equity, guarantees, cash pooling, hybrid arrangements, partnerships, trusts, funds and beneficial ownership.
- Elimination of Double Taxation: Exemption and credit methods, foreign tax credits, timing and character mismatches, source conflicts and triangular cases.
- Integrated Withholding & FTC Case: Determine source-state tax, treaty limitation and residence-state relief for a cross-border payment chain.
Session Outcome: Participants should be able to classify common cross-border income, identify withholding exposure and work through double tax relief.
Module 2 · Day 4 · 3.5 Hours
Transfer Pricing, BEPS, MLI & International Structuring
Transfer Pricing, Anti-Abuse Rules and Structure Design
- Transfer Pricing & Associated Enterprises: Arm's length principle, functional analysis, TP methods, comparability, intangibles, services, financing and business restructurings.
- Anti-Avoidance, BEPS & MLI: Treaty shopping, conduit structures, substance, PPT, LOB, hybrid mismatch themes, interest limitation, CFC concepts and treaty changes through the MLI.
- International Tax Structuring & Restructuring: Branch vs subsidiary, holding, financing and IP models, regional hubs, principal structures, repatriation, acquisitions, exits and reorganisations.
- Structure Design Workshop: Evaluate a multinational structure through treaty, PE, TP, substance and anti-abuse lenses.
Session Outcome: Participants should be able to connect transfer pricing and treaty rules with modern anti-abuse standards when reviewing international structures.
DAY 5
MODULE 3 · 2 LEARNING HOURS
Module 3 · Day 5 · 2 Hours
Digital Economy, Pillar Two, Disputes & Final Capstone
Global Minimum Tax, Tax Certainty and Integrated Analysis
- Digital Economy & Global Minimum Tax: Digital business models, evolving nexus, Pillar One overview, Pillar Two/GloBE, IIR, UTPR, QDMTT, STTR and treaty interaction.
- Dispute Resolution, Cooperation & Transparency: MAP, arbitration concepts, exchange of information, TIEAs, assistance in collection, tax certainty, documentation and reporting.
- Final International Tax Capstone: End-to-end case covering treaty access, PE, withholding, transfer pricing, double tax relief, BEPS and structuring considerations.
Session Outcome: Participants should be able to analyse an international tax problem end to end and identify the treaty, PE, TP, relief, BEPS and global minimum tax issues in one framework.
