Double Tax Treaties

This Double Tax Treaties course explores the structure of double tax treaties and their interaction with domestic law. It looks at the impact of the multilateral instrument signed by over 100 countries, which inserted significant changes to double tax treaties as a result of the OECD BEPS programme. It also examines the impact of case law, such as the right to claim unilateral relief and the recognition of foreign taxes (Aozora and Swift Cases).

The course includes:

• 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

• Double Tax Treaties and Employment Income

• Double Tax Treaties and Pensions

• Recent case law

• OECD BEPS project and the Primary Purpose Test

Case Studies The course will include two case studies: one from a corporate tax perspective and one from a personal tax perspective.

• Corporate tax case study: Explore the tax treatment of a company that is resident outside the UK but creates a permanent establishment in the UK. It examines the potential for double taxation and how this would be relieved under a double tax treaty, which the UK has signed with the relevant country. It also examines the withholding taxes that might be levied and the most tax-efficient treatment of them.

• Personal tax case study: Assess the challenges faced in preparing tax returns where individuals have overseas income and gains. It also examines the challenge of accounting for employment tax in more than one jurisdiction.

Many accountants believe that they do not need to have an awareness of double tax treaties. But if their clients derive income or have chargeable gains in more than one country, an understanding of double tax treaties is essential for completing accurate tax returns.

Training Objectives

Training enables participants to use and interpret Double Tax Treaties:

• Understand the structure and purpose of double taxation treaties (DTTs).

• Recognise differences between treaties and their impact on cross-border tax.

• Explain how DTTs interact with domestic tax law and recent case law.

• Understand Social Security agreements and their effect on taxation.

• Apply anti-avoidance rules, including the OECD BEPS Primary Purpose Test.

• Assess how DTTs affect employment income, pensions, and non-domiciled individuals.

• Use practical case studies to identify and resolve double taxation issues.

Training Course Summary

Redcliffe Training's Double Tax Treaties course provides a practical overview of double taxation treaties, their structure, variations, and the impact of Social Security agreements. Key topics include anti-avoidance measures, employment and pension income under treaties, recent case law, and the OECD BEPS project with its Primary Purpose Test. By focusing on real-world issues and diverse Social Security structures, the course offers valuable insights for professionals dealing with international tax matters.