OECD Model Tax Convention - Analysing the Mechanism of Tax Treaties and their Interaction with Domestic Tax Law
After the training the participant shall be able to:
- have a clear understanding of the mechanism used in tax treaties to allocate taxing rights and to eliminate double taxation
- understand the interaction of tax treaty law and domestic tax law based on case studies
- develop an understanding of anti-abuse provisions such as the Principal Purpose Test (PPT), subject to tax and switch-over clause
- have a view of the treatment of income and capital categories relevant for international investments and business activities (Articles 1 – 13, 21 – 23 of the OECD Model Convention)
- Introduction to tax treaties
- Double taxation
- Legal aspects and interpretation of tax treaties
- Structure, scope and mechanism of tax treaties
- Taxation of income and capital
- Income from immovable property (Art. 6)
- Business profits (Art. 7)
- Shipping, inland waterways transport and air transport (Art. 8)
- Associated enterprises (Art. 9)
- Dividends (Art. 10)
- Interest (Art. 11)
- Royalties (Art. 12)
- Capital gains (Art. 13)
- Other income (Art. 21)
- Capital (Art. 22)
- Methods for the elimination of double taxation
- Exemption method (Art. 23 A)
- Credit method (Art. 23 B)
- Rationale behind the methods
- Overview of the special provisions
- Anti-abuse provisions (PPT, subject to tax clause, etc.)
- Case studies
A qui s'adresse la formation?
Professionals of the financial sector and in-house tax managers that would like to develop a clear understanding of tax treaties and their interaction with domestic tax law.
Apart from the mechanism of tax treaties, the potential impact of the anti-hybrid mismatch rules on Alternative Investments (Real estate, private equity, etc.) and multinational groups that manage their investments via a Luxembourg investment platform.
At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.
Le contenu de ce descriptif de formation est de la seule responsabilité de son auteur, l'organisme de formation House of Training.