Paper 1 – IT

PAPER 1 – PRINCIPLES OF INTERNATIONAL TAXATION


  • Course location: Kazakhstan, Russia, Slovakia, Czech Republic, Hungary, Brazil, South Africa
  • Lecturer: JUDr. Tomas Balco, LL.M., FCCA
  • Price: depends on location of the course
  • Duration:  6 days
  • Materials: hard copy of study materials and access to online library

COURSE DESCRIPTION:

Preparatory course for Paper 1 – Principles of International taxation is carried out in 2 models:

  • Introductory course, which consits of 4 days of trainings
  • Revision course, which consits of 2 days of trainings

Introductory course is intended to establish sound theoretical foundation for all the ADIT syllabus areas which will be also combined with practical application of the theory on practical cases.  This session is also suitable for tax practitioners, who do not wish to have ADIT qualification but are interested to advance their understanding of international tax issues, such as tax treaty application and interpretation, use of anti-avoidance rules and basics of tax planning and transfer pricing.

Revision course is designed to assist students to further develop ADIT exam technique and is focused on reviewing the critical areas of syllabus on real exam questions to enhance their chances of passing the exam.

CONTENT OF INTRODUCTORY COURSES

    Day 1: Basic principles of international tax law  

  • 1.1. Tax jurisdiction
  • 1.2. Types of double taxation and  its causes
  • 1.3. Methods for elimination of double taxation
  • 1.4. History of international tax law
  • 1.5. Private international law and taxation

    Day 2: Double Taxation Conventions  

  • 2.1. Structure of tax treaties and key principles
  • 2.2. Review of the main articles
  • 2.3. Key definitional provisions – Residence concept, PE concept
  • 2.4. Interpretation of Double Taxation Conventions
  • 2.5. Methods of elimination of double and taxation and dispute resolution technique

    Day 3: Transfer pricing and thin capitalization rules  

  • 3.1.  Attribution of profits to PEs and associated enterprises
  • 3.2. Transfer pricing and Article 9 in the Model Tax Conventions
  • 3.3. OECD Transfer Pricing Guidelines
  • 3.4. Overview of BEPS initiative and recent developments in respect of Transfer Pricing

    Day 4: Tax avoidance  and miscellaneous topics  

  • 4.1. Domestic law approaches to tax avoidance (CFC, Thin-Cap, and other rules)
  • 4.2. International tax practice to limit anti-avoidance schemes and recent OECD developments
  • 4.3. Cooperation between tax authorities
  • 4.4. Overview of BEPS initiative and recent developments in respect of general IT issues
  • 4.5. Miscellaneous topics

In-house training are available. Please contact Our Team for further details at office@tomiver.com 


Contact Our Team at office@tomiver.com to register for preparatory ADIT courses.

Consult CIOT website for deadlines to register for ADIT exams!


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