International Taxation Training Course.

Introduction

International taxation plays a pivotal role in global business operations, affecting cross-border trade, investment, and corporate structuring. This 5-day course provides a comprehensive understanding of international tax laws, principles, and strategies. It focuses on how multinational corporations and individuals navigate the complexities of tax jurisdictions, tax treaties, and compliance. The course also explores key international tax issues such as transfer pricing, VAT/GST, and the taxation of foreign income.

By the end of the course, participants will be equipped with the knowledge to manage international tax risks, structure cross-border transactions, and ensure compliance with global tax regulations.

Course Objectives

• Understand the fundamental principles of international taxation and its application to businesses and individuals.
• Learn the concepts of tax treaties, withholding tax, and tax residency.
• Gain proficiency in transfer pricing and its impact on multinational companies.
• Understand VAT/GST systems and their application in international trade.
• Learn how to manage cross-border tax risks and ensure tax compliance.

Who Should Attend?

• Tax professionals, accountants, and legal advisors dealing with cross-border tax issues.
• Corporate finance executives, CFOs, and compliance officers in multinational corporations.
• Financial professionals involved in global mergers, acquisitions, and joint ventures.
• Students and professionals seeking to specialize in international tax law and finance.

Day 1: Introduction to International Taxation

• Session 1: Fundamentals of International Taxation
  • Overview of international tax systems: jurisdictional issues and tax treaties.
  • Tax residence and the impact of residency rules on taxation.
  • Principles of double taxation and the role of tax treaties in mitigating it.
  • The OECD Model Tax Convention: an overview of the most widely used tax treaty model.
• Session 2: Cross-Border Taxation
  • Taxation of foreign income: how different jurisdictions tax foreign income (e.g., repatriation of profits).
  • The role of the country of origin and the country of residence in taxation.
  • The impact of foreign tax credits and deductions on tax liabilities.
  • Withholding tax on cross-border payments: dividends, interest, and royalties.
• Session 3: Double Taxation and Tax Treaties
  • Principles of double taxation relief: credit method vs. exemption method.
  • Overview of bilateral tax treaties and the relief they provide.
  • How tax treaties prevent double taxation and allocate taxing rights between countries.
  • The impact of tax treaties on cross-border transactions: interpreting and applying treaties.

Day 2: Transfer Pricing and Multinational Tax Strategies

• Session 1: Introduction to Transfer Pricing
  • What is transfer pricing? Definition and relevance for multinational corporations.
  • The arm’s length principle: how it governs transfer pricing.
  • Common transfer pricing methods: Comparable Uncontrolled Price (CUP), Cost Plus, and Resale Price.
  • How transfer pricing impacts global tax liabilities and reporting.
• Session 2: Transfer Pricing Documentation and Compliance
  • Transfer pricing documentation requirements in various jurisdictions.
  • The role of local file and master file documentation as per OECD guidelines.
  • Common transfer pricing risks: audits, adjustments, and penalties.
  • How to manage tax audits and disputes related to transfer pricing.
• Session 3: Advanced Transfer Pricing Techniques
  • Intangible assets and transfer pricing: intellectual property, patents, and royalties.
  • Transfer pricing for financial services and intra-group financing.
  • Profit split method and cost-sharing arrangements.
  • Case studies: transfer pricing issues in global business operations.

Day 3: Value-Added Tax (VAT) and Goods and Services Tax (GST) in International Trade

• Session 1: Introduction to VAT/GST Systems
  • What is VAT/GST? Overview of how VAT and GST systems work.
  • Key differences between VAT and sales tax.
  • The VAT/GST chain: registration, invoicing, and payment.
  • The role of VAT/GST in cross-border transactions: imports, exports, and exemptions.
• Session 2: VAT/GST and Cross-Border Transactions
  • Taxable and exempt cross-border transactions: how VAT/GST applies to international trade.
  • The concept of the “place of supply” and its impact on VAT/GST treatment.
  • VAT/GST refunds, credits, and exemptions for international transactions.
  • Managing VAT/GST in a multinational organization: risks, compliance, and planning.
• Session 3: International VAT/GST Compliance
  • VAT/GST registration requirements for businesses operating across borders.
  • Filing and reporting requirements for VAT/GST in different jurisdictions.
  • Common compliance challenges in international VAT/GST: digital goods, e-commerce, and services.
  • Managing VAT/GST audits and disputes.

Day 4: International Taxation in the Digital Economy

• Session 1: Taxation of Digital Services and E-Commerce
  • The challenge of taxing digital services in the global economy.
  • OECD’s efforts to address tax challenges in the digital economy: Pillars 1 and 2.
  • The taxation of digital platforms, digital advertising, and data use.
  • Global trends in taxing the digital economy: Digital Services Taxes (DST) and other emerging taxes.
• Session 2: E-Commerce and VAT/GST on Digital Goods
  • VAT/GST compliance for e-commerce businesses: selling digital goods and services cross-border.
  • Digital marketplace taxation: how platforms like Amazon, eBay, and others are affected by VAT/GST.
  • Managing VAT/GST on digital sales: reporting, invoicing, and payment.
  • International e-commerce regulations: cross-border taxation of internet sales and services.
• Session 3: OECD Digital Tax Framework and Future Trends
  • Overview of OECD’s digital tax framework and international tax reform efforts.
  • The impact of digital taxation on multinational companies and the broader economy.
  • Future trends in digital tax: international collaboration, taxation of digital advertising, and new forms of digital business.
  • Case studies of countries implementing digital taxes: EU, UK, and other global jurisdictions.

Day 5: Compliance, Planning, and Risk Management in International Taxation

• Session 1: Tax Compliance in Cross-Border Transactions
  • Understanding tax reporting requirements: FATCA, CRS, and other global tax compliance initiatives.
  • How to manage compliance in multiple jurisdictions: coordinating filings, tax returns, and audits.
  • The role of tax advisors in ensuring compliance with international tax rules.
• Session 2: International Tax Planning Strategies
  • Tax-efficient structuring of cross-border operations: holding companies, joint ventures, and subsidiaries.
  • Use of tax treaties to minimize withholding taxes and tax liabilities.
  • Transfer pricing and the importance of aligning pricing with business substance.
  • Tax planning for multinational corporations: managing profit allocation, cross-border financing, and IP ownership.
• Session 3: Managing International Tax Risks
  • Identifying and managing risks in international taxation: audits, penalties, and regulatory scrutiny.
  • The impact of changing tax regulations on international businesses.
  • Case study: assessing tax risk and opportunities in a global corporate structure.

Course Conclusion

• Recap of Key Learnings
• Interactive Q&A Session
• Certification of Completion
• Networking Opportunity