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International Tax Update

The new environment for international taxation

Debt Structuring using Cash Flow Modelling Training Course

A one-day course

This course provides a new approach to corporate tax taking into account the substantial changes arising from the BEPS (Base Erosion Profit Shifting) project. This course takes the 15 objectives of the OECD and looks at the changes in the international tax system that have arisen as a consequence of BEPS and other developments. These include changes in rules regarding:
  • Residence
  • Permanent Establishment
  • Interest
  • Hybrid instruments
  • Transfer Pricing
  • Double Tax Treaties
  • Information requirements
This course looks at the way these recommendations are being implemented. It also looks at the changing international corporate tax environment.

This course will:

  • Update participants on current developments on the international effects of BEPS
  • Update participants of developments arising from case law
  • Update participants on the effect of BREXIT and Covid-19
  • Enable understanding of the methodologies used in transfer pricing
  • Enable participants to interpret and use double tax treaties

At the end of the course, participants will have a good knowledge of the 15 principles of BEPS and their consequences for their clients.

We also look at the effect of BEPS internationally, not just in the UK.

Loss Relief

  • Principles of claiming loss relief
  • Time limits
  • Special provisions for dual resident companies or entities
  • Loss carry back
  • Loss reliefs within the EEA

Double Tax Agreements

  • Principles underlying double tax agreements
  • Scope of DTA
  • The OECD model
  • Domestic versus Treaty Relief

Corporate Interest Restrictions (CIR)

  • OECD Principles
  • Definition of terms including EBIDTA and interest
  • Fixed Ratio Rules
  • Worldwide Group Ratio Rules
  • Group Reporting Rules
  • Administration calculations

Hybrid Instruments

  • Hybrid payers defined
  • Hybrid payees defined
  • Hybrid instruments
  • Tax Authority counteractions

Transfer Pricing

  • Changes to Transfer Pricing as a result of BEPS
  • Methods by which a company can defend its position
  • Pricing models and generally accepted practices and how they differ across OECD countries
  • Recent case law
  • Documentation requirements

Residence and Permanent Establishment

  • OECD changes to permanent establishment definitions
  • Residence issues as a result of the Development Securities case
  • Impact of Covid-19 on residence

International Tax Developments in 2021

  • President Biden’s tax proposals
  • Base Erosion Profit Shifting (BEPS 2.0) the second round of OECD tax reform
  • BREXIT the Trade and Cooperation Agreement-the ongoing tax implications
  • Transfer Pricing changes
  • G7 agreement on corporation tax reform for large companies
  • Other major tax changes in 2021

Case Studies

The case study will look at the typical challenges that a company will face in managing its tax strategy, for example, double tax relief, loss relief, and financing arrangements.  

Participation by the delegates

In the light of the global minimum corporation tax rate agreed at the G7 in June 2021 participants will be asked to reflect on how recent changes to international corporate tax will affect their strategy and that of their clients.

The trainer is a 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 but his particular interests include employment taxation and transfer pricing, which poses unusual conceptual challenges.

Previous to this he worked for Henderson for nearly 9 years, leading the Share Schemes team for part of this time.

He took the level 7 CIPD Masters qualification whilst 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. It was so unusual at the time that the Revenue phoned him up to find out how they could encourage more large companies to adopt SIP.

The trainer started his career in taxation and for the next 16 years worked in three of the “Big Four” accountancy firms. 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.

The creation of a planning system for tax professionals to control the transfer pricing planning process. This is an advanced course for those who understand the basic principles of transfer pricing.

This course is suitable for Finance Directors, Chief Financial Operators, Senior personnel within the taxation department and any other key personnel who have responsibilities for Transfer Pricing policies and their implementation.

  • Good range of topics and not too long spent on each

Have this course presented In-House

  • On a date, time and in a location of your choice
  • Topics expanded or deleted to your bespoke requirements
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Have this course pre-recorded

  • Full course recording edited exclusively for your company
  • Files converted to enable housing on your LMS
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