International taxation (C3050) - Blended learning
- Understand the principles of international taxation.
- Learn about the taxation of residents and non-residents under Luxembourg domestic tax law.
- Be aware of forms and reasons of double taxation and understand the role of tax treaties as a means to avoid double taxation.
- Learn about the taxation of specific kinds of income: interest, dividend, capital gain and intellectual property rights.
- Know about the applicability of tax treaties and learn to analyse taxing rights allocated under the OECD Model Convention as well as triangular tax cases in a tax treaty context.
- Understand the methods for elimination of double taxation.
- Be aware of tax aspects of extraordinary transactions such as mergers.
- Get an overview of the Special provisions of the OECD Model Convention and get acquainted with international tax planning.
- Taxation of residents and non-residents under Luxembourg tax law.
- Double taxation reasons for double taxation and forms thereof.
- Introduction to tax treaties purpose and mechanism.
- Scope of tax treaties (including tie-breaker rules and definitions).
- Income from Immovable property (Article 6) and business profits (Article 7) including an overview of the permanent establishment concept (Article 5).
- Shipping, inland waterways transport and air transport (Article 8), Associated enterprises (Article 9) and Dividends (Article 10) including triangular cases.
- Interest (Article 11), Royalties (Article 12), Capital gains (Article 13) and triangular cases thereof.
- Articles 15 22 of the OECD-MC.
- Methods for elimination of double taxation (Articles 23 A and 23 B).
- Special provisions provided in the OECD-MC (Articles 24 29).
A qui s'adresse la formation?
Beginners of tax advisory firms and tax practitioners who aim to develop a good understanding of international taxation.
None. However it is recommended to complete the module "Corporate income tax" (C3049E) prior to enroling to this module or to have equivalent knowledge.
Le contenu de ce descriptif de formation est de la seule responsabilité de son auteur, l'organisme de formation Luxembourg Lifelong Learning Centre de la Chambre des salariés.