This three-day intermediate-level course focuses on international tax planning structures of multinational corporations following recent international developments, such as the Base Erosion and Profit Shifting (BEPS) Project, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and the new OECD Transfer Pricing Guidelines.
The course is designed to provide participants who deal with international tax planning with the latest updates on tax treaty and transfer pricing developments relevant to their day-to-day work. It covers, through a combination of formal presentations and case studies, the practical implications these recent developments may have on existing structures that rely on tax treaties and highlights the risks associated with their use in the post-BEPS world.
• Setting the scene
• OECD multilateral instrument
• The MLI in practice - an example
• Substance considerations in international tax planning
• Substance and permanent establishments
• Substance in global value chains
• Recent EU anti-tax avoidance developments
• Unilateral BEPS-motivated domestic law measures
• Transfer pricing post-BEPS
• Case studies