Double Tax Treaties

This Double Tax Treaties course explores the structure of double tax treaties and their interaction with domestic law. It looks at the impact of the multilateral instrument signed by over 100 countries, which inserted significant changes to double tax treaties as a result of the OECD BEPS programme. It also examines the impact of case law, such as the right to claim unilateral relief and the recognition of foreign taxes (Aozora and Swift Cases).

The course includes:

• Interpreting Double Taxation Treaties
• Variations in the structure of double tax treaties
• Social Security agreements
• Anti-avoidance developments
• Reform of the taxation of non-domiciled individuals
• Double Tax Treaties and Employment Income
• Double Tax Treaties and Pensions
• Recent case law
• OECD BEPS project and the Primary Purpose Test

Case Studies

The course will include two case studies: one from a corporate tax perspective and one from a personal tax perspective.

• Corporate tax case study: Explore the tax treatment of a company which is resident outside the UK but creates a permanent establishment in the UK. It examines the potential for double taxation and how this would be relieved under a double tax treaty, which the UK has signed with the relevant country. It also examines the withholding taxes which might be levied and the most tax-efficient treatment of them.
• Personal tax case study: Assess the challenges faced in preparing tax returns where individuals have overseas income and gains. It also examines the challenge of accounting for employment tax in more than one jurisdiction.

Many accountants believe that they do not need to have an awareness of double tax treaties. But if their clients derive income or have chargeable gains in more than one country, an understanding of double tax treaties is essential for completing accurate tax returns.

The course leader is the director of a consultancy company specialising in taxation, share scheme advice, reward and lecturing. He has developed a specialised share scheme service for small companies and advises FTSE companies on communication. The lecturing covers most aspects of Direct Taxation. His particular interests include employment taxation and transfer pricing, which pose unusual conceptual challenges.

Previously, he worked for Henderson for nearly 9 years, leading the Share Schemes team for part of this time. The trainer took the level 7 CIPD Masters qualification at Henderson. Before Henderson, he was with Australia Mutual Provident (AMP) and helped set up one of the first Share Incentive Plans (SIP) for large companies in 2001.

He began his career in taxation and worked in three of the “Big Four” accountancy firms for the following 16 years. He ended up as a Senior Manager with Deloitte & Touche, having worked on issues such as profit-related pay, share schemes, expatriate tax, tax investigations, reward management, US taxation, transfer pricing and corporate tax.

This training enables participants to use and interpret Double Tax Treaties:

• Understand the structure and purpose of double taxation treaties (DTTs).
• Recognise differences between treaties and their impact on cross-border tax.
• Explain how DTTs interact with domestic tax law and recent case law.
• Understand Social Security agreements and their effect on taxation.
• Apply anti-avoidance rules, including the OECD BEPS Primary Purpose Test.
• Assess how DTTs affect employment income, pensions, and non-domiciled individuals.
• Use practical case studies to identify and resolve double taxation issues.

This Double Tax Treaties course explores DTTs from a practical standpoint, including looking at the very different Social Security structures.

This course is suitable for anyone who deals with globally mobile individuals, taxpayers with overseas interests and investments, multi-national companies and businesses with international interests.

Redcliffe Training's Double Tax Treaties course provides a practical overview of double taxation treaties, their structure, variations, and the impact of Social Security agreements.

Key topics include anti-avoidance measures, employment and pension income under treaties, recent case law, and the OECD BEPS project with its Primary Purpose Test.

By focusing on real-world issues and diverse Social Security structures, the course offers valuable insights for professionals dealing with international tax matters.