Overview of subjects and teachers
(subject to change)
Monday 25 April
Key concepts of international tax law
First, we will explore why and how countries tax cross-border income and the double taxation that will typically result therefrom (juridical and economic double taxation). Next, the various methods to relieve juridical double taxation will be examined: both their operation and their advantages & disadvantages. Finally, a brief overview is presented of the types of relief countries may offer regarding economic double taxation.
teachers: morning: ITC Leiden – Prof. Kees van Raad | afternoon: IFA-India – To be announced
Tuesday 26 April
Introduction to tax treaties & treaty residence
The interaction between the distributive articles and the double taxation relief provisions will be examined and explained, along with the key concepts of residence and source. ‘Residence’ will be further examined in some detail.
teachers: morning: ITC Leiden – Prof. Kees van Raad | afternoon: IFA-India – To be announced
Wednesday 27 April
Business profits taxation under tax treaties
The main topics of this comprehensive subject that will be visited include the contents and application of the distributive rules of OECD Model Article 7: the main rule and the exception if business is conducted through a `permanent establishment´ (PE) in the other state. Further, the concept of PE will be examined in some detail (physical PE, project PE, Agency PE; other non-OECD types of PE).
teachers: morning: ITC Leiden – Prof. Kees van Raad | afternoon: IFA-India – To be announced
Thursday 28 April
Dividends, interest & royalties and immovable property income & capital gains under tax treaties
The tax treaty rules on investment income vary with the nature of the investment. Immovable property income is typically subject to ordinary taxation in the source country whereas income from intangible rights (shares, debts, intellectual property rights) is usually subject to flat-rate gross-basis taxation in the source country with the residence country taxing it again with a tax credit provided for the source country tax. The taxation of investment income gives rise to numerous theoretical and practical issues the most important ones of which will be touched upon in this day’s topic.
teachers: morning: ITC Leiden – Prof. Kees van Raad | afternoon: IFA-India – To be announced
Friday 29 April
Income from employment, pensions, etc. under tax treaties
The grown mobility of labor has greatly increased the importance of OECD Model Articles 15 through 20, each of which deals with a particular type of service income. The main rules are laid down in Article 15 which gives rise to a variety of important issues in international tax practice. In addition to an analysis of some of these issues, other points arising under the rules on the remuneration of directors, pensions, and the income of artistes and sportsmen will be discussed.
teachers: morning: ITC Leiden – Prof. Kees van Raad | afternoon: IFA-India – To be announced
Saturday 30 April
Five fundamental rules on tax treaty application and various advanced case studies
The interaction between domestic tax law (on which a country’s actual taxation is based) and a tax treaty is quite particular, and in tax practice often gives rise to misunderstanding and mistakes. Today’s class in the first place deals with this issue in a detailed and analytical fashion. The remainder of the day we will be dealing with comprehensive cases from international tax practice. In these cases advanced theoretical issues arise which will be discussed in some detail, along with the interaction between topics that earlier in the week were analyzed separately.
teachers: morning: ITC Leiden – Prof. Kees van Raad | afternoon: ITC Leiden – Prof. Kees van Raad