Rapenburg 65, 2311 GJ Leiden

Phone +31 (0) 71 - 751.01.30

Fax +31 (0) 71 - 751.01.31

Rapenburg 65, 2311 GJ Leiden

Phone +31 (0) 71 - 751.01.30

Fax +31 (0) 71 - 751.01.31

                                                                               

2017 ITC Summer Course in Brazil

Introduction 
In February 2017 ITC Leiden will offer for the third time in Brazil an international tax law program that will be taught mostly in Portuguese (but also in English).
–  06-10 February 2017:  Tax Treaties
–  13-17 February 2017:  Advanced subjects
–  20-24 February 2017:  Transfer Pricing

Program
Based on the Summer Course which ITC organizes in Leiden each year in July, the Brazilian course (with a schedule that has been slightly adjusted to include important recent legal developments in Brazil) will cover in particular the following topics:

Week 1 (Tax Treaties)  – 06-10 February 2017
                  o Key concepts of international tax law
                  o Introduction to tax treaties & treaty residence
                  o Business profits taxation under tax treaties
                  o Dividends, interest & royalties and immovable property income & capital gains under tax treaties
                  o Income from employment, pensions, etc. under tax treaties

Week 2 (Advanced  subjects)  – 13-17 February 2017
                  o Five fundamental rules on tax treaty application & triangular cases
                  o Double tax relief and non-discrimination issues under tax treaties
                  o Beneficial ownership and tax treaty anti-avoidance provisions
                  o Brazilian CFC rules (Law 12,973/13)
                  o Transfer pricing issues
                  o Advanced issues on business profits taxation under tax treaties and the amended Art 7 OECD Model 2010

Week 3 (Transfer Pricing)  – 20-24 February 2017
                  o OECD Transfer Pricing Guidelines (4 days)
                  o Regional TP Practices (1 days)

For a detailed overview of the Program click here. And for the CVs of the teachers click here.

Location
The Summer Course takes place in São Paulo at the following location:
CEU-IICS Escola de Direito (Instituto Internacional de Ciências Sociais)
Rua Martiniano de Carvalho, 573 (Free parking available for participants at Rua Santa Madalena 75)

Class hours
Class hours are 9.00–12.45 and 14.00–17.00 (lunch included for participants at the course venue).

Language
A few classes will be taught in English (by Prof. Kees van Raad and other foreign teachers) but most are given in Portuguese (by Brazilian teachers, all of them alumni of the ITC Leiden).

Tuition fee & discounts 
The tuition fee for the three-week program: BRL 13,125  (fee does not include accommodation).  

The tuition fee amounts for the individual weeks are:
•   Week 1 (Tax treaties) BRL 5,500  (5 days)
•   Week 2 (Advanced subjects) BRL 6,000  (5 days)
•   Week 3 (Transfer pricing) BRL 6,000  (5 days)

The tuition fee for the first two weeks includes readers and the following two books: 
•   Arnold, International Tax Primer (KLI, 2016) 
•   Van Raad (ed.), Vol. A (Int’l Tax Law) of Materials on International, TP & EU Tax Law 2016-2017 (ITC Leiden). 

Participants registering for the third week receive the reader for that week plus: 
•   Van Raad (ed.), Vol. A (Int’l Tax Law) of Materials on International, TP & EU Tax Law 2016-2017 (ITC Leiden). 

Discounts
•   Two-week discount: Persons registering for any two weeks receive a 10% discount.
•   Early bird discount: An (additional) 10% discount is available for those whose tuition fees are received before 25 December 2016.
•   Group registration: Groups of three or more persons who make a joint single payment of the overall amount due: an (additional) 10% discount. 
•   Previous years’ students: Students that have already attended any of the individual weeks in previous editions of the course may also benefit from a      discount of 25% off.
•   CEU-IICS Escola de Direito: Teachers and students of the CEU-IICS Escola de Direito: 30%.
•   Sponsoring firms: partners and associates of sponsoring firms: 20%
•   Associates of the IBDT: a 10% discount applies

Please note: the discounts cannot be combined, except those that are marked `(additional)´.

Registration
Click here for registration.

Further information
Brazil.Summercourse@itc-leiden.nl



main sponsor Loyens & Loeff