Tax Treaty Case Law

When:
Tuesday, 06 December 2016
(09.00 a.m. – 05.00 p.m.)

Where:

DDTC Academy
Menara Satu Sentra Kelapa Gading 5th Floor,
Unit #0501
Jl. Boulevard Kelapa Gading LA3 No.1 Summarecon
Kelapa Gading Jakarta Utara 14240

Investment:
IDR 3.000.000

SAVE!

• 15% discount will give if cost has been paid at least 20 days before the starting date of the training.
• All participants of DDTC Academy will get “Kartu Peserta Training”. Get 20% discount for subscribe the next training programs and valid until December 2016. (for only 3 (three) more training programs).
• Registrant must choose between the msot advantageous discount option. Only one discount is available at the time a registration is made.

Background:
Tax treaties are considered as an instrument to relief double taxation. However, the application of tax treaties between taxpayer and tax authority may be differ due to their understanding of the treaty interpretation. In this regards, tax treaty disputes becomes not avoided and both taxpayers and tax authority will seek all relevant arguments, including the preceding tax court decisions, to resolve these disputes.

With the continuously increasing importance of tax treaties, our practical course provides participants with the international tax knowledge in order to resolve their problem based on the precedent of court decisions. Cases presented are not only from the decisions of the Indonesian tax court, but also important tax treaty cases were decided around the world. This course is a valuable reference tool for tax practitioners who interested in tax treaty case law. Each case will be presented in a systematic structure that allows easy and efficient comparison for participants.

Topics Covered:

• The Relationship of Tax Treaties and Domestic Law;
• Core Disputes in the Active Income Arena (Permanent Establishment, Business Profits, Income from International Shipping and Air Transport, Dependent Personal Services, Artist and Sportsmen, etc.);
• Core Disputes in the Passive Income Arena (Income from Immovable Properties, Dividend, Interest, Royalties, etc.);
• Selected Cases in the Eligibility of Treaties (Certificate of Domicile and Partnership);
• Selected Treaty Abuse Cases.