ADIT Diploma
22,000EGP

ADIT Diploma
MODULE 1 – PRINCIPLES OF INTERNATIONAL TAXATION
I Basic principles of international tax law 20%
- Jurisdiction to tax, including limits to tax jurisdiction arising from public international law, and cross border enforcement of taxes
- Taxes and tax systems
- State practice in exercising tax jurisdiction
- Causes of international double taxation
- Methods of relief from international double taxation
- Private international law and tax
- The history of international tax law
- European Union law and international tax
- Tax and international human rights instruments
- State responsibility in international tax – the development of the concept of harmful tax competition
II Double taxation conventions (DTCs), focusing on the current version of the OECD Model Tax Convention (MTC) 30%
Candidates are expected to: understand the operation of the provisions of the OECD MTC; show awareness of the major points in the Commentary to the relevant Article of the OECD MTC; and be aware of key reports of the OECD Committee on Fiscal Affairs and major international cases on the topic.
- Types of DTCs (limited, multilateral etc.) and negotiation of DTCs
- DTCs and domestic law
- Format and structure of a DTC
- Approach to the application of a DTC: applying a DTC to a concrete scenario
- Interpretation of DTCs
- Provisions relating to the scope of a DTC: Articles. 1, 2, 29, 30, 31 and 32
- Key definitional provisions
- DTC provisions relating to businesses
- DTC provisions relating to individuals
- DTC provisions relating to investment income and gains
- Relevance of the “other income” Article – Article 21, OECD MTC
- Limitation of benefit provisions
- Methods of elimination of double taxation – Articles 23A and 23B, OECD MTC
- The impact of the non-discrimination article – Article 24, OECD MTC 2
- The resolution of disputes under DTCs
- The application of DTCs to electronic commerce
- The digital economy
- The work of the Platform for Collaboration on Tax
- The work of the UN Committee of Experts on International Cooperation in Tax Matters
III Transfer pricing and thin capitalization rules 20%
- Various approaches to the determination of profits of branches and associated enterprises
- State practice with respect to transfer pricing
- Transfer pricing and DTCs – Article 9, OECD MTC
- Advanced pricing agreements
- The OECD Transfer Pricing Guidelines 2017
- Transfer pricing and BEPS
- Transfer pricing and developing countries
- State practice with respect to thin capitalization
- Thin capitalization legislation and DTCs
IV International tax avoidance 25%
- Tax havens
- Domestic law approaches to international tax avoidance
- Money-laundering legislation and international tax avoidance
- Co-operation between revenue authorities
- Conventions for administrative assistance in tax administration
- Base Erosion and Profit Shifting (BEPS)
V Miscellaneous topics 5%
- Indirect taxes and international taxation
- Cross-border mergers
- Estate and gift taxation and international issues
- OECD Secretariat analysis of tax treaties and the impact of the COVID-19 crisis
Course Features
- Lectures 0
- Quizzes 0
- Duration 80 hours
- Language ENG/AR
- Students 0
- Assessments Yes