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2018 ITC Summer Course in Brazil

to be held in São Paulo
15 January – 2 February 2018 (three weeks)

General information
In January 2018 ITC Leiden will offer for the fourth time in Brazil an international tax law program that will be taught mostly in Portuguese (but also in English)

The ITC Summer Course in Brazil has been set up for tax professionals from Portuguese-speaking countries who typically work with either the government or in private practice or a company’s tax department and who want to expand their knowledge of international tax law.  The reason to offer this program in addition to the existing Adv LLM Program offered by ITC Leiden in the Netherlands is that the latter program may be too lengthy (12 months) and/or too costly (current tuition fee: € 19,000) for many interested tax experts in Brazil and Portugal.  Therefore, ITC Leiden has taken the initiative to organize a three-week program which features the essentials of the two main courses of the 12-months ITC Leiden’s Adv LLM Program (i.e., the Tax Treaties course and the Basic Transfer Pricing course). 

The Program comprises courses taught by teachers of ITC Leiden (incl. Prof. dr. Kees van Raad) and a few invited renowned scholars. Most classes are taught in Portuguese, with the exception of those taught by Prof. Kees van Raad himself or other foreign teachers (given in English). 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:

First week:  Transfer pricing  
•  Introduction to  arm’s length principle & Traditional Transaction Methods
Transactional Profit Methods
Intra-group services and economic analysis
•  Intangible property and CCA
Brazilian domestic application of transfer pricing rules

Second week:  Tax treaties
Key concepts of international tax law
• Introduction to tax treaties and treaty residence
Business profits taxation under tax treaties
• Dividends, interests & royalties and immovable property income & capital gains under tax treaties
The OECD/G20 Multilateral Instrument &Income from employment, pensions, etc. under tax treaties

Third week:  Advanced subjects
Five fundamental rules on tax treaty ans advanced subjects
Double tax relief and non-discrimination issues under tax treaties
Brazilian CFC rules (Law 12,973/14)
• Transfer pricing issues
Advanced issues on business profits taxation under tax treaties and the amended Art. 7 OECD Model 2010

For a detailed overview of the program click here.

Full program or single weeks
While the Program is offered as a three-week program, each of the three weeks can be registered for individually.   

Firms are invited to check with Alexandre Siciliano (alexandre.siciliano@loboderizzo.com.br) for interesting registration/sponsoring arrangements.

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 (Transfer pricing)       BRL 6,000
Week 2 (Tax treaties)               BRL 5,500
Week 3 (Advanced subjects)      BRL 6,000

The tuition fee for the first two weeks includes one reader for each week and the following book:
Van Raad (ed.), Vol. A (International Tax Law) of: Materials on International, TP & EU Tax Law 2017-2018 (ITC Leiden). 

Participants registering for the third week receive the reader for that week plus:
Van Raad (ed.), Vol. B (TP Tax Law) of: Materials on International, TP & EU Tax Law 2017-2018 (ITC Leiden). 

Two-week discount: Persons registering for any two weeks receive a 10% discount.
Early bird discount: An (additional) 10% discount is available if the tuition fee is received before 25 December 2017.
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.
Sponsoring firms: partners and associates of sponsoring firms: 20%.
Associates of the IBDT: a 10% discount applies.
Teachers and students of the IBDT: a 30% discount applies

Please note: the discounts cannot be combined, except those that are marked ‘(additional)’

Period and hours
The program takes place from Monday 15 January through Friday 2 February 2018.  Classes and workshops are held 9.00 – 12.00 h and 13.30 – 16.30 h Monday through Friday.  The late afternoons and evenings are to be used by the students for reviewing that day’s class and preparing for next day’s class.  

Executive Certificate
Those who attend at least 80% of the class hours will be issued by ITC Leiden a Certificate of Attendance. 

Instituto Brasileiro Direito Tributário (`IBDT´), Av. Brigadeiro Luís Antônio, 290 – Bela Vista, São Paulo, Brazil.   

Cancellation policy
–  Cancellation more than 30 days before the beginning of the Program: full refund minus a cancellation fee of BRL 1,000.
–  Cancellation within 30 days after the Program start: no refund but the person registered may be substituted.

Further information 
Feel free to contact the Brazil Summer Course Program Coordinator at ITC at Brazil.Summercourse@itc-leiden.nl.

Application / registration
This registration has expired.