Training Objectives

By the end of the programme, participants will be able to:

• Identify and analyse the interaction of tax systems arising from cross border transactions.
• Name the main concepts and principles of international taxation.
• Describe Worldwide Tax system, Territorial Tax System and Mixed Tax System.
• Identify the various sources of income and understand the concepts of residence and source jurisdictions.
• List and explain the possible cases of double taxation and the available elimination methods.
• Describe the OECD MTC and its vital role in the interpretation of the Double Tax Treaties.
• Identify the various anti-avoidance regimes.
• Correlate the different anti-avoidance regimes and understand how they are interacting.
• Develop a practical approach of analysing business cross border transactions.
• Substantiate the impact of domestic and international tax law on cross border transactions.
• Acquire knowledge and practical understanding of international tax systems and implications in Cyprus tax regime.
• Perform practical analysis of the impact of the source and residence jurisdictions on various sources of income.
• Explain the concept of permanent establishment as defined in the OECD model.
• Defend taxpayers in case of double taxation.
• Develop the necessary competencies needed in interpreting double tax treaties.
• Explain the impact of anti-avoidance regimes for taxpayers.
• Analyse the impact of relevant taxes on various domestic and foreign transactions and courses of action, including the interaction of Cypriot and foreign taxes.
• Evaluate and understand the operation and function of the various tax systems in the context of the international tax sphere.
• Compare Worldwide Tax system, Territorial Tax System and Mixed Tax System and evaluate their strengths and weaknesses.
• Evaluate the impact of the existence of a Permanent Establishment in the taxation of MNEs profits.
• Understand the applicability of the Permanent Establishment in the Digital age.
• Appraise double taxation issues and eliminate double taxation by applying the provisions of Tax Treaties.
• Evaluate the major provisions of the OECD Model tax treaty and their application in hypothetical situations.
• Motivate the usage of double tax treaties in dealing with complex cross border transactions.
• Appraise the effect of Anti Avoidance Regimes and Anti Avoidance Provisions in domestic and international tax law.

Training Outline

International Taxation

An Introduction to international taxation as it derives from the different tax systems applicable to each country and cross border transactions.

• International Tax Definition
• Major Principle of cross border transactions
• Theory of Tax Law
• Examples of domestic and international tax implications – Case study and class discussion

Tax Systems and Policy Considerations

An explanation of the types of tax systems, mainly Worldwide Tax system, Territorial Tax System and Mixed Tax System, and an analysis the main components of these systems to understand the tax system of each country.

• Definitions of the tax systems
• International tax theory – concepts
• Interaction of tax systems arising from cross border transactions

Tax Systems and Policy Considerations

• Case study and class discussion

Source of Income, Residence Status, Tax Jurisdictions

An introduction to the fundamental principles of source of income and residence status that derive from the tax systems covered in the previous session, and also introduces the concept of tax jurisdictions (right to impose taxes) for enabling the participants to indicate the tax system applicable in each jurisdiction and to identify double taxation issues. Furthermore, the methods of eliminating double taxation will be introduced

• Explanation of source of income, residence status and tax jurisdictions.
• Explanation of the concept of permanent establishment per the OECD model
• Double Taxation
• Methods of elimination

Source of Income, Residence Status, Tax Jurisdictions

• Case study and class discussion

Double Tax Treaties –  the concept of double tax treaties and their interpretation

• Definitions
• Explanation of OECD and UN Treaty Models
• Interpretation of double tax treaties

Anti Avoidance Regimes and Anti Avoidance Provisions

An explanation of the different anti avoidance regimes and provisions that are applicable in most countries

• Definition of tax evasion and tax avoidance
• CFC rules
• Tax haven rules
• Thin capitalization
• Black and White lists Limitation of benefits

Anti Avoidance Regimes and Anti Avoidance Provisions

• Case study and class discussion

Who Should Attend

The programme is ideal for:

• CFOs
• Directors
• Senior Managers
• Tax Consultants
• Chief Accountants
• Financial Controllers
• Lawyers
• C-Level Executives and Senior Managers in Investment Firms
• Internal Lawyers
• External Auditors, Lawyers and Financial Consultants

Training Style

The training style is training-focused, involving a combination of presentation and real-life examples, but also learner-focused, where participants are encouraged to raise questions, seek clarifications and share their opinions from their different perspectives and engage in an exchange of views and personal professional experiences.

It will strive to enhance participants’ skills and knowledge via presentations, discussion, questions, brainstorming and practical examples.

Explanation of the necessary theory behind the practice shall be made whilst then progressing with a focus on the documents and procedures.  Role play and brainstorming shall also be applied during delivery.

CPD Recognition

This programme may be approved for up to 14 CPD units in Accounting and Auditing. Eligibility criteria and CPD Units are verified directly by your association, regulator or other bodies which you hold membership.

In-house Training

For groups within the same organisation, this course may be customized to meet any specific needs and delivered in-house.