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Intensive Course: INTERNATIONAL TAX PLANNING Centre for International Fiscal Studies Cd Rom containing beyond 1000 pages of materials and the slides of the 4 modules of Intensive Course of International Tax Planning held from 22 to 25 February 2005 in Shanghai. CHF 1 500.- plus TVA and shipment expenses

INTRODUCTION

• Main definitions
• Introduction to sources of international tax law
• Treaties against double taxation
• Elimination of double taxation
• Problems linked with the activity of an international tax advisor
• Analysis of a project of tax planning
  
  
  SOURCES OF INTERNATIONAL TAX LAW

• Treaties against double taxation
• Structure of the OECD Tax Treaty model
• Interpretation of the OECD Tax Treaty model
• Prevention of tax evasion
• Elimination of double taxation
• USA Tax Treaty model
• Principles of European tax law

  APPLICATION OF SOURCES

• Problems linked with the elimination of double taxation
• Exemption method
• Credit method
• Relations between tax treaties and national fiscal law
• Analysis of case histories

  INDIVIDUALS

• Residence of individuals
• The fictitious residence
• Problems linked with the change of residence
• The "Exit tax"
• Tax planning of the transfer of residence of individuals

  TRUSTS

• General concepts
• Trust in Common Law Countries
• Trust in Civil Law Countries
• Hague Convention on recognition of Trust
• Problems of Trust taxation

COMPANIES

• Fiscal residence of companies
• Analysis of the concept of permanent establishment
• Coparative analysis permanent establishment - subsidiary
• Comparative analysis of the main holding companies regulations

  
  INTERNATIONAL TRANSFER PRICE

• The problem of transfer price
• Methods to calculate transfer price
• Tax ruling on transfer price
• TAX PROBLEMS OF E-COMMERCE
• The new Commentary to art. 5 of the OECD Tax Treaty model against double taxation
• Problems of international e-commerce
• New tipes of tax avoidance and tax evasion
• USA position
• New European VAT Directive on e-commerce

  
  LAW ON PREVENTION OF TAX AVOIDANCE AND TAX EVASION

• Distinction between anti avoidance and anti evasion laws
• OECD position
• EU position
• Rule shopping and treaty shopping
• Analysis of case histories