Rapenburg 65, 2311 GJ Leiden
Phone +31 (0) 71 - 751.01.30
Rapenburg 65, 2311 GJ Leiden
Phone +31 (0) 71 - 751.01.30
June 2019 ITC Leiden China Summer Course in International Tax Law at the School of Economics of Fudan University and taught by Prof. dr. Kees van Raad.................................................................19 06 11
1. Duration of ITC Leiden Summer Course and language of instruction
Period: Monday 24 June – Friday 28 June 2019 (exam in evening of Saturday 29 June).
Language of instruction: The morning lectures are in English. The afternoon workshops are conducted in Chinese.
The course is taught in the morning hours by prof. dr. Kees van Raad, professor of International Tax Law at the Leiden University Law School, chairman of the International Tax Center Leiden and director of its Adv LLM Program in International Tax Law. The afternoon workshops will be given by Shaomei Chen who graduated in 2016 from Leiden University’s Adv LLM Program in International Tax Law as nr. 1 of her class (she is currently a PhD student at Leiden University). Practitioners, university teachers, government tax officials and PhD students (not: regular students) have the choice to participate one afternoon in a seminar given by prof. dr. Kees van Raad on tax treaty case studies.
Students that are interested in competing for the (full and partial) tuition fee scholarships for the ITC Leiden 2020-2021 Adv LLM Program which are available for the three students with the best results in the exam that is given at the end of the program, are strongly advised not to miss the afternoon workshops. The knowledge and insight tested at the exam deals with the issues that are explained in some detail in these workshops. Only (full-time) students may compete for these scholarships which are provided by ITC Leiden (one full and two half tuition fee scholarships).
3. Course subjects
3.a. Regular course subjects
– International tax jurisdiction
– International juridical & economic double taxation
– Relief from international:
> juridical double taxation: exemption & foreign tax credit
> economic double taxation of dividends: in case of:
– direct foreign investment: participation exemption and indirect foreign tax credit
– and portfolio foreign investment: various methods
– Introduction to tax treaties and treaty residence
– Business profits taxation under tax treaties
– Dividends, interest & royalties and capital gains taxation under tax treaties
– Income from employment under tax treaties
– Introduction to transfer pricing
To prepare for the course, the participants are suggested to read through Articles 1-21 (with the exception of Articles 2, 8 and 9) of the OECD Model Tax Convention on Income and on Capital (2017) and its Commentaries on these Articles. The OECD Model Tax Convention (2017) including the Articles and Commentaries can be accessed on the website of the OECD.
3.b. Seminar: 'Digital Silk Road - AI, big data, and platforms, what the international digital tax proposals mean for China'
The seminar, scheduled on the morning session of Friday 28 June, is given by Mr. Sam Sim, Senior Advisor at the University of Vienna Institute for Austrian and International Law Global Tax Policy Center, Member of Practice Council at New York University School of Law, Member of Income Tax Review Board and Board Member of Tax Executive Institute Asia.
Mr Sim was Regional Vice-President (Europe, Middle-East, Africa, Asia and Latin America), Tax Executive Institute and chair of Capital Markets Tax Committee Transfer Pricing sub-committee. He has led global teams as Deputy Global Head of Transfer Pricing at a leading European MNE and Transfer Pricing Geo Leader for EMEA and Asia-Pacific in the largest US global Technology MNE. He hears income tax cases as a member of the Income Tax Review Board chaired by a Principal District Judge. He has multiple board level appointments including on audit and risk and disciplinary committees.
He is passionate in digital taxation and transfer pricing and researched on AI and Taxation at the Center for Artificial Intelligence at SMU, co-authored IEEE and IBM Research papers on Blockchain and lectured at the Master of Tax programme at Singapore University of Social Science, University of Leiden's Executive Tax Program, Vienna University’s Transfer Pricing course, IBFD programmes and is the author of The Logic and Practice of Transfer Pricing (Lexis-Nexis), Singapore Transfer Pricing Masterguide 2018/19 (CCH) and Editor of Asia Voices: BEPS and Beyond (IBFD). He was a tax attorney in New York, a CPA and holds graduate degrees in Law (NYU LL.M.(Tax), Economics (M.A., Cambridge University) and Accounting (MPA, SMU).
4. Time table
– Arrival registration (and distribution of course materials): Sunday 23 June 2019 between 1 p.m. and 6 p.m. (i.e., on the day before the course begins)
– Opening Ceremony: Monday 24 June 2019, 8:30 a.m.
– Classes: Monday 24 June – Friday 28 June 2019:
8:30 a.m. – 12 p.m. (lecture) & 1:00 – 4:00 p.m. (workshop)
– Exam: Saturday 29 June 2019, 6.30 - 10.00 p.m.
5. Requirements for enrollment in the Summer Course
Admission to the ITC Leiden’s China Summer Course is open to the following categories of persons:
a. university students who are pursuing (i) an undergraduate degree with a specialization in tax law (or taxation), economic law or financial accounting, or (ii) a master or doctoral degree in tax law (or taxation), or in finance;
b. university teachers of tax law, taxation and financial accounting;
c. government tax officials, and
d. tax practitioners in private practice or working in a corporate tax department.
Participants of all categories need to meet the following requirements:
>> proven English proficiency: minimum score of 500 for National English test level six (CET6); or minimum overall score of 7 for IELTS or 100 for TOEFL, and
>> adequate tax knowledge based on either tax courses taken at the university or tax practice experience.
Enrollment in the 2019 ITC Leiden’s China Summer Course at Fudan is restricted to 100 students. If the total number of student applications received by the deadline date (20 June 2019) exceeds the 100 places available, students with better academic records will be given priority. There is no number restriction for university teachers, government officials and practitioners.
Because of this restriction on the number of students that are admitted, students that have attended an ITC-China Summer Course in a previous year may not enroll again this year.
6. Exams, certificates, diplomas and scholarships
Participants that attend at least 75% of all the lectures & workshops (attendance will be checked every morning and afternoon) will receive a certificate of attendance issued jointly by the International Tax Center Leiden and the School of Economics of Fudan University. If a participant obtains an exam grade of at least 5.0 (on a scale 0 – 10) instead of just a certificate of attendance s/he will be issued a diploma (stating that the candidate has passed the exam). Further, participants that obtain an exam grade of at least 7.0 will be given a diploma with honors.
There will be two exams. The five students that have obtained the highest grades in the first exam (on Saturday 29 June 2019) are invited to take a second exam that takes place within two months after the first exam. Whereas the first exam primarily tests the level of understanding of subjects that have been taught in the lectures and workshops, the second exam goes beyond that. The second exam examines whether students on the basis of the concepts they have studied during the course, are also able to analyze higher-level issues that were not necessarily discussed during the course. From the experience of past years, it is clear that the best students of the first exam are not necessarily the students who get the best grades in the second exam, due to the difference in focus between the two exams. Therefore, the individual ranking obtained by the five best students in the first exam will not be released as this would provide an incorrect impression of a student’s chance in the second exam. The (combined) result of the two exams will be released to the five students shortly after the second exam.
The five students that have taken the second exam will be requested to send in their IELTS test scores before the end of December 2019. As a rule, the student with the highest weighted average grade of the two exams will, provided s/he has a sufficient IELTS or TOEFL test score, be granted a full tuition scholarship for the 2020-2021 academic year of the ITC Leiden Adv LLM Program (value € 20,000). The two students ranking 2 and 3 will be granted a half tuition fee scholarship (value € 10,000) for the 2020-2021 ITC Leiden Adv LLM program (entitling them to participate in the courses taught during the period September through January).
A student with a half tuition fee scholarship may of course pay the additional tuition fee amount and complete the full year Program. If the average grades of the three top students are rather close, the tuition fee scholarships may be divided in a manner different from what is indicated above.
A student who wins a full or partial ITC Leiden tuition fee scholarship is allowed to postpone her/his study in Leiden for one year (and study in Leiden during the 2021-2022 academic year).
The monthly cost of living for a Chinese student in Leiden typically ranges from € 600 to € 1000 per month, depending on individual lifestyle.
7. Summer Course fee
Participation in the Summer Course (including course materials) is free for students. Other participants (university teachers, government officials and tax practitioners) will be charged a course fee:
– RMB 1,500 for university teachers and government officials, and
– RMB 3,000 for tax practitioners.
Applicants must submit:
a. a resume (including her/his latest GPA – the average result of all the grades achieved throughout her/his degree),
b. proof of English proficiency (National English test level six [CET6], IELTS or TOEFL score), and, optionally,
c. a digital version of articles they have published in a (Chinese or English) tax periodical (and/or books.
before 20 June 2019 by email to: Mr. Yu, at GGJJ@fudan.edu.cn
A list of the persons participating in the course will be posted at http://www.econ.fudan.edu.cn/graduatelist.php?page=1&pid=344