Course Detail(TAX157 : Unravel The Knots in Tax Treaties)

TAX157 : Unravel The Knots in Tax Treaties

3.50 CPE Hours (Others)
Classroom

Programme Objective

With business becoming progressively international, there are many transactions that involve cross border parties. With different parties in different countries, the tax system of one country may differ from another thus giving rise to tax issues that need to be resolved. Some countries have concluded tax treaties which attempt to bring some resolution to these issues in the international tax arena.

This course will give the participants an understanding of the framework of what tax treaties are, how they work and the major specific issues addressed in the tax treaties.  We will be analysing specific definitions and articles to discuss the purpose of tax treaties, what they mean, how they work, the benefits as well as the pitfalls in tax treaties.

Programme Outline

(a) Purpose of tax treaties (b) The OECD Model Convention(c) Base Erosion Profit Shifting 
  • Coverage of treaty
  • Words and phrases defined
  • Avoidance of double taxation of income
  • Recognition of income source
  • Right of taxation (Source v Residence)
  • Benefits of tax treaty
  • Limitations of benefits
  • Discussion and interpretation of specific terms
  • Analysis of the tax treaty articles and inter-play of the articles
  • Exchange of information by governments
  • Inter-governmental resolutions
  • Concern over profit shifting exercises
  • The BEPS action steps to prevent profit shifting
  • Limiting base erosion via interest deductions and other financial payments
  • Preventing non-taxation of income
  • Dealing with treaty shopping

Training Methodology
Lecture style.
 
Closing Date for Registration
1 week before programme or until full enrolment. 

Intended For

Basic to Intermediate programme intended for tax students, In-house tax accountants/analysts, tax seniors, tax professionals, finance managers.

Competency Mapping

Others = 3.50 Hours

Schedule & Fees

Date & Time

18 Oct 2019 (2:00 PM - 5:30 PM)

Fee (inclusive of GST)

For Members: $ 199.02
For Non-Members: $ 237.54

Programme Facilitator(s)

Peter Tan

Venue

60 Cecil Street
ISCA House
Singapore 049709

Date & Time

08 Dec 2018 (9:00 AM - 12:30 PM)

Registration is closed

Programme Facilitator(s)

Peter Tan

Date & Time

21 Jul 2018 (9:00 AM - 12:30 PM)

Registration is closed

Programme Facilitator(s)

Peter Tan

Date & Time

09 Sep 2017 (9:00 AM - 12:30 PM)

Registration is closed

Programme Facilitator(s)

Peter Tan

Testimonial

Funding

No funding Available!

Programme Facilitator(s)


Peter Tan

Peter is a Barrister from the Middle Temple, Inns of Court, London where he was called to the Bar of England. He started his tax career in London and continued his specialism in Singapore with KPMG and subsequently with PwC. He was later a Senior Tax Consultant with Baker & McKenzie, Wong & Leow but now runs his own boutique tax and transfer pricing practice, PeterTanConsulting Pte Ltd.

He has advised many MNCs from various industries such as financial institutions, manufacturing, IT, transport and logistics covering areas such as international taxation, mergers & acquisitions, group and business restructuring,  joint venture projects, intellectual property transactions, franchising and distribution, supply chain, financial products, transportation & logistics, tax incentives and transfer pricing. He has also extensive experience in dealing with tax controversies and has obtained several tax rulings.

Peter has been named a leading tax advisor in Singapore for several years and has been named in the tax controversy field by International Tax Review.

 

Programme Objective

With business becoming progressively international, there are many transactions that involve cross border parties. With different parties in different countries, the tax system of one country may differ from another thus giving rise to tax issues that need to be resolved. Some countries have concluded tax treaties which attempt to bring some resolution to these issues in the international tax arena.

This course will give the participants an understanding of the framework of what tax treaties are, how they work and the major specific issues addressed in the tax treaties.  We will be analysing specific definitions and articles to discuss the purpose of tax treaties, what they mean, how they work, the benefits as well as the pitfalls in tax treaties.

Programme Outline

(a) Purpose of tax treaties (b) The OECD Model Convention(c) Base Erosion Profit Shifting 
  • Coverage of treaty
  • Words and phrases defined
  • Avoidance of double taxation of income
  • Recognition of income source
  • Right of taxation (Source v Residence)
  • Benefits of tax treaty
  • Limitations of benefits
  • Discussion and interpretation of specific terms
  • Analysis of the tax treaty articles and inter-play of the articles
  • Exchange of information by governments
  • Inter-governmental resolutions
  • Concern over profit shifting exercises
  • The BEPS action steps to prevent profit shifting
  • Limiting base erosion via interest deductions and other financial payments
  • Preventing non-taxation of income
  • Dealing with treaty shopping

Training Methodology
Lecture style.
 
Closing Date for Registration
1 week before programme or until full enrolment. 

Intended For

Basic to Intermediate programme intended for tax students, In-house tax accountants/analysts, tax seniors, tax professionals, finance managers.

Competency Mapping

Others = 3.50 Hours

Programme Facilitator(s)

Peter Tan

Peter is a Barrister from the Middle Temple, Inns of Court, London where he was called to the Bar of England. He started his tax career in London and continued his specialism in Singapore with KPMG and subsequently with PwC. He was later a Senior Tax Consultant with Baker & McKenzie, Wong & Leow but now runs his own boutique tax and transfer pricing practice, PeterTanConsulting Pte Ltd.

He has advised many MNCs from various industries such as financial institutions, manufacturing, IT, transport and logistics covering areas such as international taxation, mergers & acquisitions, group and business restructuring,  joint venture projects, intellectual property transactions, franchising and distribution, supply chain, financial products, transportation & logistics, tax incentives and transfer pricing. He has also extensive experience in dealing with tax controversies and has obtained several tax rulings.

Peter has been named a leading tax advisor in Singapore for several years and has been named in the tax controversy field by International Tax Review.

 


Upcoming Schedule

Date & Time

18 Oct 2019 (2:00 PM - 5:30 PM)

Fee (inclusive of GST)

For Members: $ 199.02
For Non-Members: $ 237.54

Programme Facilitator(s)

Peter Tan

Venue

60 Cecil Street
ISCA House
Singapore 049709