Course description
International taxation is among the crucial concerns for a lot of growing businesses and people around the globe. There is a constant need to understand the international taxation system and the transfer of pricing among modern-day businesses and people to save on tax expenditures and reduce costs. It is also important to master and understand key concepts of international taxation and transfer pricing in this technological age where world trade is interconnected using technology.
Upcoming start dates
Suitability - Who should attend?
Who should attend?
The Certificate Course in International Taxation and Transfer Pricing by Rcademy is ideal for the following professionals:
- Lawyers
- Entrepreneurs
- Custom servants
- Management consultants
- CA
- Business owners
Outcome / Qualification etc.
The aims of The Certificate Course in International Taxation and Transfer Pricing by Rcademy are to enable participants to:
- To acquire skills related to tax systems used by individuals, businesses, and companies
- Explain and accurately calculate the effects of the tax on incorporated and unincorporated businesses
- Identify the main tax principles used effectively to create a framework for international taxation
- Appreciate where there is a potential taxation leakage and mispricing
- Discover the UN tax model agreements and OECD and develop the required knowledge to handle tax treaty problems with improved confidence
- Understand how to utilize various tools and techniques tax experts use to identify and handle problems arising from transfer pricing
- Explain in detail how local tax laws and techniques govern transfer pricing
Training Course Content
Module 1: Introduction to International Taxation and Transfer Pricing
- Importance of transfer pricing laws
- What is international taxation?
- Arm’s length pricing
- Principles and techniques of direct taxation and their effects in developing a cross-border framework
- International tax treaties and domestic tax laws interactions
Module 2: Transfer Pricing Techniques
- Effective transactional methods – The famous Comparable uncontrollable price method (CUP) – Resale pricing technique – Cost-plus technique
- Advanced transfer pricing (APA)
- Adjustment of transfer prices and taxable profits
- Withholding taxes and double taxation relief
- Non-transactional methods – Net margin transitional technique – Profit split technique
Module 3: Transactions Involved in Transfer Pricing
- Carbon trading
- Cash pooling
- Payments and netting services
- Provision of financial guarantees
- Factoring and forfeiting of receivables
- Captive insurance of group risks
- Asset management of surplus cash
- Arranging global credit facilities
Module 4: International Taxation
- Model treaties and their principles (OECD and UN)
- Negotiations through tax treaty competent authority
- Capitalization rules and domestic tax evasion
- Multinationals and tax management
- The diverted profits tax
- International taxation exemptions
Module 5: Handling International Taxation
- International gas and oil pipelines – Tax – Legal – Tariff problems
- Cross-border resource investments
- Extractive investments and tax treaties
- Corporate taxation and extractive industries – Best practices – Principles and – Issues
- Fiscal issues for cross-border natural resources projects
Module 6: International Financial Management
- The implication of international taxation
- Foreign corporate equity
- Case study: – Observations by Greece and Spain
Module 7: Treaties Benefits
- Economics of international trade
- Worldwide international tax systems
- The main problem with international taxation
- Taxing rules
- Branch profits tax
Module 8: Source Rules
- Income source rules
- Dividends (foreign payor)
- Rentals and royalties
- Residence for source rule purposes
- Services
- Portfolio interest
- Taxation of a foreign government
- Information reporting
Module 9: Foreign Tax Credit
- The statutory framework
- Creditable taxes – Levy tax – Income tax
- Eligibility
- Computing the direct credit
- Foreign tax credit limitations
- Interest expense allocation rules change
- Functional foreign currency
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Rcademy
Rcademy is a global training and consultation organisation set out to bridge the gap between you now and what you can be in the near future. We are facilitators of knowledge impartation. Our team of established and experienced training enthusiasts...