Learning Objectives
7 objectives- Understand the fundamental principles and objectives of international taxation and distinguish it from domestic taxation.
- Analyze various methods to avoid double taxation, including tax treaties, foreign tax credits, and exemption methods.
- Examine transfer pricing principles, regulations, and their impact on multinational corporations.
- Evaluate the role of tax havens, tax evasion, and tax avoidance in the international tax landscape.
- Understand Base Erosion and Profit Shifting (BEPS), Controlled Foreign Corporations (CFCs), and Permanent Establishments (PE) concepts and their implications.
- Develop knowledge of tax compliance and reporting requirements for international transactions.
- Apply theoretical knowledge to real-world international taxation scenarios through case studies.
Content Outline
PreviewUnit 1235: International Taxation
1. Introduction to International Taxation
1.1 Principles and Objectives
- Definition and scope of international taxation
- Key principles: residence, source, and jurisdiction
- Objectives: preventing tax evasion, equitable taxation, and fiscal sovereignty
1.2 Domestic vs. International Taxation
- Differences in scope and application
- Interaction between domestic laws and international tax rules
- Challenges unique to international taxation
2. Double Taxation Avoidance Methods
2.1 Concept of Double Taxation
- Types: juridical and economic double taxation
2.2 Tax Treaties
- Purpose and structure of Double Taxation Avoidance Agreements (DTAAs)
- Model conventions (OECD, UN)
2.3 Foreign Tax Credits
- Mechanism and calculation
- Limitations and carryover rules
2.4 Exemption Method
- Full and partial exemption approaches
- Application in different countries
3. Transfer Pricing
3.1 Principles of Transfer Pricing
- Arm's length principle
- Methods for determining transfer prices
3.2 Regulations and Compliance
- Documentation requirements
- Penalties for non-compliance
3.3 Impact on Multinational Corporations
- Tax base allocation
- Risk management and strategic planning
4. Tax Havens and Tax Evasion
4.1 Tax Havens
- Definition and characteristics
- Legal frameworks and secrecy laws
4.2 Tax Avoidance vs. Tax Evasion
- Definitions and distinctions
- Ethical and legal implications
4.3 International Efforts to Combat Tax Evasion
- Transparency initiatives
- Blacklists and sanctions
5. Base Erosion and Profit Shifting (BEPS)
5.1 Overview of the OECD BEPS Project
- Objectives and key actions
5.2 Common BEPS Strategies
- Profit shifting techniques
- Impact on tax revenues
5.3 BEPS Implementation and Compliance
- Country-specific measures
- Role of multinational corporations
6. Controlled Foreign Corporations (CFCs)
6.1 Concept and Purpose
- Definition of CFCs
- Rationale for CFC rules
6.2 Taxation Rules for CFCs
- Inclusion rules
- Exemptions and thresholds
6.3 Implications for Global Tax Planning
- Strategies to manage CFC exposure
- Compliance challenges
7. Permanent Establishment (PE)
7.1 Definition and Importance
- Criteria for PE under tax treaties
- Types of PEs
7.2 OECD Guidelines on PE
- Interpretation and application
- Case examples
7.3 Tax Jurisdiction and PE
- Allocation of taxing rights
- Impact on multinational corporations
8. Tax Compliance and Reporting Requirements
8.1 Compliance Obligations
- Filing requirements for international transactions
- Record-keeping standards
8.2 Reporting Requirements
- Disclosure of related-party transactions
- Country-by-country reporting
8.3 Importance of Transparency
- Role in preventing tax avoidance and evasion
- Regulatory consequences of non-compliance
9. Case Studies in International Taxation
9.1 Case Study 1: Application of Double Taxation Treaties
- Scenario, analysis, and tax implications
9.2 Case Study 2: Transfer Pricing Adjustment
- Identifying issues and resolving disputes
9.3 Case Study 3: BEPS Strategies and Countermeasures
- Practical challenges and regulatory responses
9.4 Case Study 4: Compliance Failures and Penalties
- Lessons learned and best practices
Unlock the full outline
Get the complete content outline, learning outcomes and assessment methods for International Taxation.
KSh 20 one-off, or included with a plan
Learning Outcomes
Unlock the outline above to see learning outcomes.
Assessment Methods
Unlock the outline above to see assessment methods.