In a post-BEPS landscape, the interaction between domestic anti-avoidance rules and international tax treaties is more complex than ever. This course provides a roadmap for interpreting modern treaty provisions, with a focus on “Beneficial Ownership” and the “Principal Purpose Test” (PPT). The sessions examine how the Multilateral Instrument (MLI) has altered treaty application and provide practical strategies for interpreting these rules in the context of live advisory work.
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Double Tax Treaties & Anti-Avoidance Rules: Practical Interaction & Interpretation
Introduction:
Course Audience:
Specialist Tax Practitioners, Cross-border Advisers, and Senior Law Associates.
Course Requirement:
1. Treaty vs. Domestic Law Interaction;
2. Beneficial Ownership Analysis;
3. PPT & Anti-Avoidance Logic;
4. Case Studies on Modern Interpretation.
Professional Standing: Designed for Specialist Tax Practitioners, Cross-border Advisers, and Senior Law Associates.
Technical Literacy: Familiarity with the Post-BEPS landscape and the impact of the Multilateral Instrument (MLI).
Course Module:
1. Treaty vs. Domestic Law Interaction;
2. Beneficial Ownership Analysis;
3. PPT & Anti-Avoidance Logic;
4. Case Studies on Modern Interpretation.
Technical Note:
High-level technical depth required. Concise and technically grounded approach.