The Multilateral Instrument (MLI) has fundamentally changed how tax treaties are interpreted. This course provides a practical guide for UK advisers to navigate these changes. The sessions cover PE risk, anti-fragmentation rules, and the “Principal Purpose Test” as modified by the MLI. Participants will learn how to apply these new interpretations to existing and future cross-border structures.
Enquire About Technical Sessions
Speak directly with Dr. Angelo Chirulli to discuss bespoke training, in-house workshops, or upcoming course dates.
International Tax & the Multilateral Instrument: A Practical Guide for UK Advisers
Introduction:
Course Audience:
Tax Advisers, Corporate Lawyers, and International Finance Managers.
Course Requirement:
1. Understanding MLI Application;
2. PE Risk & Anti-fragmentation;
3. PPT Analysis;
4. Re-interpreting Tax Treaties.
Professional Standing: Tailored for Tax Advisers, Corporate Lawyers, and International Finance Managers.
Technical Foundation: A solid understanding of Double Tax Treaties and traditional Permanent Establishment (PE) definitions.
Course Module:
1. Understanding MLI Application;
2. PE Risk & Anti-fragmentation;
3. PPT Analysis;
4. Re-interpreting Tax Treaties.
Technical Note:
Provides a clear, technically grounded point of view on treaty changes.