Tax Treaty Interpretation and Application (Batch 6)

When:

• Batch 5 (15 July – 26 August 2017)
• Batch 6 (9 September – 21 October 2017)

Activity Time (per batch):
Every Saturday from 09.30 a.m. to 03.30 p.m

Session (per batch):
5x sessions + 1x exam

Where:
DANNY DARUSSALAM Training Center
Menara Satu Sentra Kelapa Gading 5th Floor,
Unit #0501
Jl. Bulevar Kelapa Gading LA3 No.1 Summarecon
Kelapa Gading Jakarta Utara 14240

Investment:
IDR 7.500.000 per batch.
(Click here for discount)

Background:
Tax treaties are a global phenomenon. There are over 3000 bilateral tax treaties concluded by different countries world- wide, yet the wording and structure of such treaties are to a large extent the same. As international treaties, tax treaties are subject to the same rules of interpretation as other countries.

The understanding of tax treaty interpretation and application therefore, provides unique opportunities for tax practitioners and interested parties alike. This course is designed for participants wishing to expertise in international tax laws with a perfect combination between theory and practice in concrete experience based on real cases.

Topics Covered:

• Structure of tax treaties: The application practice, interaction of domestic law and treaty law, importance of the scope of the convention term with regard to persons and taxes covered, distributive rules and methods for elimination of double taxation
• Interpretation: rule of Art. 3 (2) OECD Model Convention, relevance of OECD Commentary and modifications in practice
• Abuse of tax treaties: Where are the limits? analysis on Google Double Irish Dutch Sandwich structure, other multinationals tax structures and recent developments
• Business profits (Art.7) and connection with other distributive rules, Permanent Establishments (Art.5), Passive income (Art. 10, 11, and 12), Capital Gains (Art. 13) and indirect transfer of shares
• Income from dependent work (employees); 183 time test rule
• Artistes and Sportsmen (Art. 17), with real case examples (U2 case)