The last four years has seen a dramatic change in the international tax environment. Procedures and practices which date back over 80 years are now being challenged by revenue authorities backed up by politicians and public opinion who believe that the corporate world is not contributing sufficiently to repairing public finances.
Encouraged by public opinion and Parliamentary pressure, governments and revenue authorities are looking to tighten the way that corporate taxes are calculated and collected. Companies need to understand the new environment and how this may affect their future tax strategies.
This course naturally divides into two aspects: corporate taxation and personal taxation.
The corporate side looks at the recent developments. These include
- the establishment of GAAR’s in many countries
- the current thinking on transfer pricing
- the OECD’s base erosion and profit shifting project (BEPS)
- how revenue authorities are cooperating to attack aggressive tax avoidance
- the use of double tax treaties
- current issue is on permanent establishment
- the treatment of intellectual property
- the use of inversion to reduce overseas tax liabilities
- recent case law
The personal tax side looks at:
- changing residence rules
- domicile- what is its current relevance?
- FATCA and the other exchange of information protocols
- double tax treaties
- withholding taxes
- Social Security agreements
- treatment of share schemes for mobile employees
- how to price an individual’s services
The two parts of the course are complementary. The existence of a permanent establishment in a particular country is likely to have a knock-on effect on the personal tax position. Participants in the course will gain an insight into the trends in corporate and personal taxation as well as the remaining opportunities for tax mitigation.
The course will also look at the current environment and to what extent tax planning will still be attractive to companies and individuals, given the reputational risks that are now involved.