Course Detail(TAX193 : International Taxation: Cross-Border Tax Issues and Tax Treaties)

SDF Funding, SkillsFuture Credit

TAX193 : International Taxation: Cross-Border Tax Issues and Tax Treaties

14.00 CPE Hours (Others)
Classroom

Programme Objective

There is continuing rise in cross-border activities across various industries due to globalization.  Businesses are entering into significant commercial transactions and international projects through a range of structures and arrangements in order to gain access to new markets and resources and to share technical know-how.  This programme provides participants with a broad overview of international taxation and how this has impact on cross-border activities, arrangements and transactions that involve the movement of persons, capital, goods and services across borders.
 
The programme begins with a very brief introduction to taxation, moving on to introduce key issues in international taxation as a result of globalization where residence, source, double taxation and double tax treaties will be examined.  In the next section of the programme, participants are taken through tax considerations that must be kept in mind when one moves from doing business with another country to doing business in another country.  Here, participants begin to examine key features of the operation of double tax treaties.  As part of this section, participants will be taken through some of the ways in which differences in States’ tax systems can be exploited by taxpayers to minimize global tax liabilities, and the measures adopted by governments to combat perceived tax avoidance.  Where appropriate, the concerns of tax authorities are addressed, and wherever possible, the course seeks to advance the reasoning behind the various anti-avoidance measures affecting international groups.  Developments in international taxation in light of the OECD Base Erosion Profit Shifting (BEPS) Project are integrated into each topic as appropriate, where OECD’s main recommendations are set out and some explanation and comment on these are offered.  

Programme Outline

  • Introduction to international taxation
  • Concepts of source and residence, and a State’s right to tax
  • Taxing individuals / individuals working abroad
  • The double taxation problem – how does it arise 
  • Measures for elimination of double taxation 
  • An overview of the OECD Model Convention and the role of double tax treaties
  • Main articles of the OECD Model Convention, their interaction and interpretation
  • Permanent establishments
  • Taxation of cross-border services
  • Withholding tax - what is this and how does it arise 
  • Trading in multiple countries: structuring and tax planning strategies of multinational groups
  • International tax avoidance and the improper use of tax treaties
  • Transfer pricing
  • Developments in international taxation – exchange of information agreements and OECD Base Erosion and Profit Shifting (BEPS) – an update on how these affect you


The principal aim of this programme is to present international taxation in an accessible manner. It examines international tax principles primarily from the viewpoint of a multinational group of companies.

Designed as a Foundation to Intermediate level programme, with the commitment to providing participants with sound basic information and guidance in the subject of international taxation and what lies beneath the current complexities of international tax rules, it is the hope that the course will prove useful not only to those interested in the basics, but also serve as a building stone for more advanced courses in international taxation for those wishing to advance their knowledge of the subject of international taxation.


Training Methodology
Lecture style with Case Studies.

Closing Date for Registration
1 week before programme or until full enrolment.
 

Intended For

A Foundation to Intermediate level programme particularly useful for: • Accounting, Finance and Tax Professionals • In-house tax accountants and analysts • Mid to senior in-house advisors whose companies are planning or have started to venture overseas • Business owners and entrepreneurs identifying business opportunities who are keen to understand the tax implications of their business and expansion plans.

Competency Mapping

Others = 14.00 Hours

Schedule & Fees

Date & Time

29 Oct 2019 (9:00 AM - 5:00 PM)
30 Oct 2019 (9:00 AM - 5:00 PM)

Registration is closed

Programme Facilitator(s)

Peter Tan

Date & Time

15 Jul 2019 (9:00 AM - 5:00 PM)
16 Jul 2019 (9:00 AM - 5:00 PM)

Registration is closed

Programme Facilitator(s)

Peter Tan

Date & Time

19 Mar 2018 (9:00 AM - 5:00 PM)
20 Mar 2018 (9:00 AM - 5:00 PM)

Registration is closed

Programme Facilitator(s)

Moira Khaw

Testimonial

Funding

1] SkillsFuture Credit (SFC)
Funding Period: Until 23 November 2019
Course Ref No.: CRS-N-0041276


All Singaporeans aged 25 and above will receive an opening credit of S$500 from the government. The credits will not expire and periodic top-ups will be provided by the government. SFC may be accumulated to pay for skills related course fees. You may wish to use your SFC to pay for partial/full ISCA course fees.  (For more information on the SFC scheme, please visit http://www.skillsfuture.sg/credit)

 

If you wish to enrol for the course with SFC Funding, please proceed with the following steps:

  • Step 1: Register for the course online via ISCA Portal. Upon adding to cart, the system will prompt a question “Do you wish to apply for SkillsFuture Credit?”, click “Yes” and input all required information. At the Cart page, please ensure that SFC funding is applied before clicking “Checkout”.
  • Step 2: After successful enrolment, please proceed to submit SFC claim on Skillsfuture Portal within 60 days before the course start date and obtain the necessary approval. Please submit SFC claim via SFC portal here: http://www.skillsfuture.sg/credit.

 

Failure to submit claim application and obtain necessary approval before the course start date will result in topping up of the SFC indicated for use. Please note that there will be an administrative fee of $42.80 for any revision of invoice.


2] WDA Training Grant - SDF Funding
This course is approved for SDF funding ($2 per training hour) for Company-sponsored participants only (Eligibility criteria apply). 
 
Funding Period: Until 23 November 2019
Funded Hours: 14 hours
Course Ref No.: CRS-N-0041276

If you wish to enrol participants with SDF Funding, please proceed with the following steps (For Corporate enrolments only) :

  • Step 1: Register for the course online via ISCA Portal. Upon adding to cart, the system will prompt a question “Do you wish to apply for WDA Funding?”, click Yes and input all required information. At the Cart page, please ensure that SDF funding is applied before clicking “Checkout”.
     
  • Step 2: After successful enrolment, please proceed to submit the Training Grant application via SkillsConnect Portal here: https://www.skillsconnect.gov.sg/

 

Employers of company-sponsored participants must submit training grant via SkillsConnect system to obtain training grant for course fees. You may submit the Training Grant application within the period from 30 days before the course start date to 30 days after course start date. Please note that there will be an administrative fee of $42.80 for any revision of invoice.

 

Eligibility Criteria:

  • Company must be registered or incorporated in Singapore and;
  • Applicant is taking the course for the first time.
  • Applicant must be employed, and is either Singapore Citizen or Permanent Resident of Singapore and;
  • Applicant must achieve at least 75% attendance, and pass all examinations /assessments and;
  • Applicant must be fully sponsored by the Company for all costs associated with the training and;
  • Payment has to be made via corporate means (e.g. corporate cheque, corporate GIRO, corporate credit card).

 

Programme Facilitator(s)


Moira Khaw

Moira is the founder and Principal of a tax training and consultancy firm.  She has more than 30 years of tax experience that spans practice in international (Big 8 and later, Big 6) accounting firms, as Tax Partner in a leading Singapore law firm that was founded in 1974 as a specialist tax practice, and as Associate Professor in taxation at Nanyang Technological University.


Moira has consulted for clients from a wide and diverse variety of business sectors that includes finance, real property development and investment, international manufacturing and trading, investment fund management, aircraft manufacturing and aviation, telecommunications, and the oil and gas industry.  Her experience ranges from structuring outbound investments and cross-border project financing arrangements, corporate restructuring, mergers and acquisitions, setting up of multinational business operations and global operating subsidiaries, centralizing ownership of investments and assets, licensing of intellectual property rights, and structuring joint ventures with foreign business partners, to dealing with tax treaty issues such as withholding tax and permanent establishment, often working closely with local and foreign tax and legal experts. 

In the area of contentious tax matters and disputes with the Inland Revenue Authority of Singapore, Moira has extensive experience in providing comprehensive case assessment advisory, and in successfully representing clients and making submissions and representations at negotiations with the authorities.
As Associate Professor at the Nanyang Business School, Nanyang Technological University (NBS), Moira taught both Singapore Tax, designed and taught Advanced Taxation (a course on international tax planning), and the Tax Management Course for MBA students.  She currently lectures at the Tax Management Course for MSc. (Accountancy) students at the same business school.  Moira is also Trainer with the Tax Academy as well as lectures in the M.Tax programme at UniSIM where the module she teaches examines current topics in international taxation, including OECD's Transfer Pricing Guidelines and their relationship to the relevant OECD treaty articles. 

Moira holds a LL.B and LL.M from the National University of Singapore.
 

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

There is continuing rise in cross-border activities across various industries due to globalization.  Businesses are entering into significant commercial transactions and international projects through a range of structures and arrangements in order to gain access to new markets and resources and to share technical know-how.  This programme provides participants with a broad overview of international taxation and how this has impact on cross-border activities, arrangements and transactions that involve the movement of persons, capital, goods and services across borders.
 
The programme begins with a very brief introduction to taxation, moving on to introduce key issues in international taxation as a result of globalization where residence, source, double taxation and double tax treaties will be examined.  In the next section of the programme, participants are taken through tax considerations that must be kept in mind when one moves from doing business with another country to doing business in another country.  Here, participants begin to examine key features of the operation of double tax treaties.  As part of this section, participants will be taken through some of the ways in which differences in States’ tax systems can be exploited by taxpayers to minimize global tax liabilities, and the measures adopted by governments to combat perceived tax avoidance.  Where appropriate, the concerns of tax authorities are addressed, and wherever possible, the course seeks to advance the reasoning behind the various anti-avoidance measures affecting international groups.  Developments in international taxation in light of the OECD Base Erosion Profit Shifting (BEPS) Project are integrated into each topic as appropriate, where OECD’s main recommendations are set out and some explanation and comment on these are offered.  

Programme Outline

  • Introduction to international taxation
  • Concepts of source and residence, and a State’s right to tax
  • Taxing individuals / individuals working abroad
  • The double taxation problem – how does it arise 
  • Measures for elimination of double taxation 
  • An overview of the OECD Model Convention and the role of double tax treaties
  • Main articles of the OECD Model Convention, their interaction and interpretation
  • Permanent establishments
  • Taxation of cross-border services
  • Withholding tax - what is this and how does it arise 
  • Trading in multiple countries: structuring and tax planning strategies of multinational groups
  • International tax avoidance and the improper use of tax treaties
  • Transfer pricing
  • Developments in international taxation – exchange of information agreements and OECD Base Erosion and Profit Shifting (BEPS) – an update on how these affect you


The principal aim of this programme is to present international taxation in an accessible manner. It examines international tax principles primarily from the viewpoint of a multinational group of companies.

Designed as a Foundation to Intermediate level programme, with the commitment to providing participants with sound basic information and guidance in the subject of international taxation and what lies beneath the current complexities of international tax rules, it is the hope that the course will prove useful not only to those interested in the basics, but also serve as a building stone for more advanced courses in international taxation for those wishing to advance their knowledge of the subject of international taxation.


Training Methodology
Lecture style with Case Studies.

Closing Date for Registration
1 week before programme or until full enrolment.
 

Intended For

A Foundation to Intermediate level programme particularly useful for: • Accounting, Finance and Tax Professionals • In-house tax accountants and analysts • Mid to senior in-house advisors whose companies are planning or have started to venture overseas • Business owners and entrepreneurs identifying business opportunities who are keen to understand the tax implications of their business and expansion plans.

Competency Mapping

Others = 14.00 Hours

Programme Facilitator(s)

Moira Khaw

Moira is the founder and Principal of a tax training and consultancy firm.  She has more than 30 years of tax experience that spans practice in international (Big 8 and later, Big 6) accounting firms, as Tax Partner in a leading Singapore law firm that was founded in 1974 as a specialist tax practice, and as Associate Professor in taxation at Nanyang Technological University.


Moira has consulted for clients from a wide and diverse variety of business sectors that includes finance, real property development and investment, international manufacturing and trading, investment fund management, aircraft manufacturing and aviation, telecommunications, and the oil and gas industry.  Her experience ranges from structuring outbound investments and cross-border project financing arrangements, corporate restructuring, mergers and acquisitions, setting up of multinational business operations and global operating subsidiaries, centralizing ownership of investments and assets, licensing of intellectual property rights, and structuring joint ventures with foreign business partners, to dealing with tax treaty issues such as withholding tax and permanent establishment, often working closely with local and foreign tax and legal experts. 

In the area of contentious tax matters and disputes with the Inland Revenue Authority of Singapore, Moira has extensive experience in providing comprehensive case assessment advisory, and in successfully representing clients and making submissions and representations at negotiations with the authorities.
As Associate Professor at the Nanyang Business School, Nanyang Technological University (NBS), Moira taught both Singapore Tax, designed and taught Advanced Taxation (a course on international tax planning), and the Tax Management Course for MBA students.  She currently lectures at the Tax Management Course for MSc. (Accountancy) students at the same business school.  Moira is also Trainer with the Tax Academy as well as lectures in the M.Tax programme at UniSIM where the module she teaches examines current topics in international taxation, including OECD's Transfer Pricing Guidelines and their relationship to the relevant OECD treaty articles. 

Moira holds a LL.B and LL.M from the National University of Singapore.
 

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

Registration is closed

Date & Time

29 Oct 2019 (9:00 AM - 5:00 PM)
30 Oct 2019 (9:00 AM - 5:00 PM)

Fee (inclusive of GST)

For Members: $ 620.60
For Non-Members: $ 736.16

Programme Facilitator(s)

Peter Tan

Venue

60 Cecil Street
ISCA House
Singapore 049709