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    • |
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      • — POSTGRAD —
      • International Taxation
      • Transfer Pricing
      • Conducting a TP Trial
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      • Tax Risk Management
      • — SHORT COURSES —
      • Tax Risk Management
      • Conducting a TP Trial
      • Mastering Tax Dispute Resolution in South Africa
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    Home » International Tax Programmes

    International Tax Programmes

    • The Tax Knowledge Base
    • International Tax Programmes

    INTS1001 - WEEKS 1 & 2: Introduction to International Tax (14)

    • Common Law vs Civil Law: Key Differences in International Taxation Explained
    • Navigating International Tax Without a Double Tax Treaty: FATCA, BEPS, and Transfer Pricing
    • How Brexit Impacted UK-EU Tax and Legal Relations: VAT, Customs, and Directives
    • UN Model vs OECD Model Treaty: Key Differences in Taxation for Developing Countries
    • BEPS 2.0 Developments: Impact on International Tax Trends | Pillar One & Pillar Two Explained
    • Can you give an indication of how the MAP processes work?
    View all 14 articles

    INTS1002 - Week 17: Introduction to Anti-Avoidance (1)

    • What is the consensus in anti-avoidance legislation between countries within the EU, such as low-tax countries like Bulgaria?
    View 1 article

    INTS1002 - Week 18: Treaties (4)

    • What happens when the tie-breaker rules do not work, and there is a dispute?
    • Please give examples for Notified Jurisdiction Areas (NJA)? What happens if you have to trade within such jurisdictions?
    • How are inter-company activities treated within NJA (Tax Haven) or OECD grey-listing?
    • Are the intercompany activities taken into consideration in relation to economic substance regulation? Are they counted as a part of the necessary volume of activity and employment?
    View all 4 articles

    INTS2001 - WEEKS 23 & 24: Jurisdiction of Tax Extended (4)

    • DTAA Article 13(1): Capital Gains Tax on Sale of Property-Rich Holding Company
    • How is the tax jurisdiction handled in the case of digital nomads who have not stayed in a dwelling for more than 183 days?
    • In the case of individuals, how is the jurisdiction of tax handled within the EU when the border can be crossed at any time ?
    • In the case of businesses, are there instances where both place of management and place of incorporation tests fail?
    View all 4 articles

    INTS2001 - WEEKS 25 & 26: Double Tax/ Foreign Tax Relief (2)

    • Can you please give examples where treaty interpretation differs in cases of double taxation and double non-taxation?
    • How are foreign tax credits treated in cases of significant differences in tax rates?
    View all 2 articles

    INTS2001 - WEEKS 28 - 30: Transfer Pricing Extended (7)

    • I heard that, due to the recent pandemic, comparables from earlier years (before 2020) are not advisable to use. Is there more reliable data now since we are 4 years down the line?
    • What is the solution for companies that do not have access to expensive databases or consulting?
    • I understand that there is no list of adjustments that the companies can use. However, what are the typical adjustments that draw the attention of the tax authorities?
    • Does ignoring indirect taxes in TP, like VAT or WHT, risk double/triple taxation for cost-plus firms?
    • Is analyzing related party transactions as a whole better than isolating elements for arm's length pricing?
    • Canada v. GlaxoSmithKline: Resale Price vs. CUP Method—Which Was Right for Transfer Pricing?
    View all 7 articles

    INTS2001 - WEEKS 37 - 39: Treaties Extended (3)

    • Treaties take a long time to renegotiate or cancel. How does this work in cases of conflict between countries and in cases of sanctions being imposed?
    • If a country is part of the European Union BUT not a member of the OECD - does this affect any treaties being entered into?
    • Did Brexit affect the UK's treaties network?
    View all 3 articles
    • INTS1001 - WEEKS 1 & 2: Introduction to International Tax
      • Common Law vs Civil Law: Key Differences in International Taxation Explained
      • Navigating International Tax Without a Double Tax Treaty: FATCA, BEPS, and Transfer Pricing
      • How Brexit Impacted UK-EU Tax and Legal Relations: VAT, Customs, and Directives
      • UN Model vs OECD Model Treaty: Key Differences in Taxation for Developing Countries
      • BEPS 2.0 Developments: Impact on International Tax Trends | Pillar One & Pillar Two Explained
      • Can you give an indication of how the MAP processes work?
      • Avoiding Double Taxation on Cross-Border Advisory Fees - An African Example
      • Why is Relinquishing Tax Residency More Scrutinised Than Acquiring It?
      • How does the 183-Day Rule Impact Tax Residency and When It Can Be Nullified?
      • How are source rules that consider income from where business is carried on too vague for guidance?
      • Is double non-taxation a BEPS concern, and can a multilateral instrument prevent it?
      • Can you give examples where domestic tax rules override the UN and OECD Model Treaties?
      • Can a credit be applied if US group companies are treated as disregarded entities with a tick exercise?
      • How can one stay updated with evolving local and international tax changes and react promptly?
    • INTS1002 - Week 17: Introduction to Anti-Avoidance
      • What is the consensus in anti-avoidance legislation between countries within the EU, such as low-tax countries like Bulgaria?
    • INTS1002 - Week 18: Treaties
      • What happens when the tie-breaker rules do not work, and there is a dispute?
      • Please give examples for Notified Jurisdiction Areas (NJA)? What happens if you have to trade within such jurisdictions?
      • How are inter-company activities treated within NJA (Tax Haven) or OECD grey-listing?
      • Are the intercompany activities taken into consideration in relation to economic substance regulation? Are they counted as a part of the necessary volume of activity and employment?
    • INTS2001 - WEEKS 23 & 24: Jurisdiction of Tax Extended
      • DTAA Article 13(1): Capital Gains Tax on Sale of Property-Rich Holding Company
      • How is the tax jurisdiction handled in the case of digital nomads who have not stayed in a dwelling for more than 183 days?
      • In the case of individuals, how is the jurisdiction of tax handled within the EU when the border can be crossed at any time ?
      • In the case of businesses, are there instances where both place of management and place of incorporation tests fail?
    • INTS2001 - WEEKS 25 & 26: Double Tax/ Foreign Tax Relief
      • Can you please give examples where treaty interpretation differs in cases of double taxation and double non-taxation?
      • How are foreign tax credits treated in cases of significant differences in tax rates?
    • INTS2001 - WEEKS 28 - 30: Transfer Pricing Extended
      • I heard that, due to the recent pandemic, comparables from earlier years (before 2020) are not advisable to use. Is there more reliable data now since we are 4 years down the line?
      • What is the solution for companies that do not have access to expensive databases or consulting?
      • I understand that there is no list of adjustments that the companies can use. However, what are the typical adjustments that draw the attention of the tax authorities?
      • Does ignoring indirect taxes in TP, like VAT or WHT, risk double/triple taxation for cost-plus firms?
      • Is analyzing related party transactions as a whole better than isolating elements for arm's length pricing?
      • Canada v. GlaxoSmithKline: Resale Price vs. CUP Method—Which Was Right for Transfer Pricing?
      • Which transfer pricing method suits the diamond industry, given the difficulty in accessing reliable data?
    • INTS2001 - WEEKS 37 - 39: Treaties Extended
      • Treaties take a long time to renegotiate or cancel. How does this work in cases of conflict between countries and in cases of sanctions being imposed?
      • If a country is part of the European Union BUT not a member of the OECD - does this affect any treaties being entered into?
      • Did Brexit affect the UK's treaties network?
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