International Tax Basics. Principles of OECD Model Tax Convention application

After completing the course, you will be equipped to:

• Confidently apply the Double Tax Treaties (DTT) between any countries in the world to straightforward active and passive transactions: Master the art of utilizing DTT provisions to prevent double taxation in a variety of international dealings, enhancing your ability to manage cross-border tax issues effectively.
• Resolve simple residency conflicts for individuals and legal entities: Gain the skills to address and clarify residency-related tax disputes, ensuring the correct tax treatment for both individuals and corporations based on their residency status.
• Assess the risk of permanent establishment: Learn to accurately determine situations that may constitute a permanent establishment, thereby influencing a company’s tax obligations in foreign jurisdictions.
• Identify the taxing country for salaries, director’s fees, athletes, and entertainers’ remuneration: Acquire the knowledge to pinpoint the appropriate jurisdiction for taxing employment income, directors’ fees, and performance-related earnings, navigating the complex rules governing international tax scenarios.

Module 1

The concept of international taxation, OECD, neutrality of capital export/import. Tax residency of individuals and legal entities, resolving disputes based on the OECD Model Tax Convention on Income and Capital (hereinafter referred to as “OECD Model Convention”), the concept of “source”.

Module 2

Tax jurisdiction conflicts, types of double taxation and ways to eliminate them. OECD Model Convention: interaction with national legislation, structure, key concepts, types of distributive rules.

Module 3

Taxation of active income: the concept of permanent establishment (Article 5 of the OECD Model Convention) and taxation of profits from business activities (Article 7 of the OECD Model Convention).

Module 4

Taxation of passive income: dividends (Article 10 of the OECD Model Convention), interest (Article 11 of the OECD Model Convention), royalties (Article 12 of the OECD Model Convention). Income from the sale of property (Article 13 of the OECD Model Convention).

Module 5

Taxation of individual income received in the form of salary (Article 15 of the OECD Model Convention), director’s fees (Article 16 of the OECD Model Convention), and fees for concert or sports activities (Article 17 of the OECD Model Convention).

Tutor:
Alina Huseinova

LinkedIn

USD 649 per person

For groups of 5 or more participants, a 5% discount applies.

Participation requires a basic understanding of the terms: «tax», «dividends», «royalties», «economy», «transaction», «agreement», «real estate».

The course price includes:

• Participation (online) in the event along with the instructor and other participants
• Handout materials
• Presentation slides
• A substantial number of examples and case studies (hypothetical, from practice, or from relevant court decisions of various countries)
• A list of useful literature on the topic
• A group chat (or group) on social networks with other participants for networking (depending on the composition and desire of the course participants)
• Certificate

Extras (not included):

• Renting a venue (if the training is held in-person outside your office/coworking space)
• Coffee breaks, lunches, or any other catering (if necessary)
• Transportation and accommodation costs if the training location is outside Athens (Greece)
• Extra literature (for example, printed Commentaries to the OECD Model Convention)