Introduction to International Taxation: Principles & Practice

Course Description

This intensive 5-day course provides a comprehensive introduction to international taxation principles and practices. Participants will gain a solid understanding of key concepts in cross-border taxation, including tax treaties, transfer pricing, and global tax planning strategies. The course combines theoretical knowledge with practical case studies to ensure participants can apply their learning to real-world scenarios.

Learning Objectives

• Understand the fundamental principles of international taxation
• Analyze and interpret tax treaties and their impact on cross-border transactions
• Gain insights into transfer pricing methodologies and documentation requirements
• Explore strategies for optimizing global tax positions and managing tax risks
• Develop skills to navigate complex international tax scenarios

Course Modules

Day 1: Fundamentals of International Taxation

• Overview of international tax principles
• Residence and source concepts
• Permanent establishment rules
• Introduction to double taxation

Day 2: Tax Treaties and Their Application

• Purpose and structure of tax treaties
• OECD Model Tax Convention
• Treaty interpretation and application
• Limitation on benefits provisions

Day 3: Transfer Pricing Essentials

• Transfer pricing concepts and regulations
• Arm's length principle
• Transfer pricing methods
• Documentation requirements

Day 4: Foreign Tax Credits and Anti-Deferral Regimes

• Foreign tax credit mechanics
• Controlled Foreign Corporation (CFC) rules
• Subpart F income
• GILTI and FDII provisions

Day 5: International Tax Planning and Recent Developments

• Global tax planning strategies
• Base Erosion and Profit Shifting (BEPS) initiatives
• Digital economy taxation
• Current trends and future outlook

Practical Wins for Participants

• Ability to identify and address key international tax issues in cross-border transactions
• Skills to analyze and apply tax treaty provisions effectively
• Practical knowledge of transfer pricing documentation and compliance
• Insights into optimizing global tax structures and minimizing tax risks