JJUA55295U Cancelled International and EU Tax

The first pillar of the course is the OECD and the BEPS (Base Erosion and Profit Shifting) project. The OECD Model Treaty for the Avoidance of Double Taxation its commentaries, the expected upcoming unilateralisation of Double Tax Treaties and examples of some of the many Double Tax Treaties existing. A more thorough analysis of the interpretation rules in the Vienna Convention. The BEPS refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. The course will deal with some of the implications of the digital economy on tax strategies. Over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS, see more here: http://www.oecd.org/tax/beps/beps-about.htm

The course will also deal with the implications of domestic law on interpretation, application and choices between applying Treaty relief or Domestic tax relief and the EU-initiatives on tax-avoidance, e.g. EU directives 2016/1164 on rules against tax avoidance.

The second pillar of the course is EU tax law and its impact on direct corporate taxation. This part deals with the important issues concerning EU Tax law as part of the legal system, and aspects on non-discrimination and basic freedoms. A thorough review of the corporate tax directives such as the Parent- Subsidiary Directive, the EU Interest Royalty Directive, the EU Merger Directive and the Anti-Tax Avoidance Directive will provide the necessary background for analyzing domestic as well as international tax aspects of corporate cross border transactions. An introduction relevant to transfer pricing issues will be dealt with as well as the importance of advance pricing agreements

Finally, issues concerning mutual assistance and recovery of tax claims will be addressed.