International Tax & Double Tax Treaties

Introduction

This in-person course looks at how international tax operates and at double tax treaties from primarily a UK tax standpoint.

The course is fully updated to take account of the changes to the structure of international taxation arising from the BEPS (Base Erosion Profit Shifting) changes and the adoption of these principles. It also examines the impact of Brexit and the BEPS 2.0 project.

This course is suitable for anyone who has to deal with internationally mobile individuals, non-UK domiciles and multi-national companies.

What You Will Learn

This in-person course will cover the following:

UK Taxes Under Domestic Law, Internationally Mobile Individuals & Multinational Corporations

This part of the course looks at how the UK taxes under domestic law, internationally mobile individuals and multinational corporations.

This includes:

• Residence for personal tax and the statutory residence test
• Domicile: the new rules
• Changes to the taxation of property affecting non-UK residents and non-UK domiciles

Who Should Use Double Tax Treaties & When?

Having established the UK domestic position, the course will then explore whether double-tax treaties can be used to mitigate those liabilities.

It will include:

• The impact of the multilateral instrument which inserted significant changes to double tax treaties
• The impact of case law such as the right to claim unilateral relief and the recognition of foreign taxes (Aozora and Swift)
• Interpreting double taxation treaties
• Variations in the structure of double tax treaties
• Social security agreements
• Anti-avoidance developments
• Reform of the taxation of non-domiciled individuals
• Employment Income
• Pensions
• Recent case law
• OECD BEPS project