Topics 9
Introduction to International Taxation
Overview of the principles, concepts, and objectives of international taxation. Explore th...
Double Taxation Avoidance Methods
Premium content - upgrade to unlock
Transfer Pricing
Premium content - upgrade to unlock
Tax Havens and Tax Evasion
Premium content - upgrade to unlock
Base Erosion and Profit Shifting (BEPS)
Premium content - upgrade to unlock
Controlled Foreign Corporations (CFCs)
Premium content - upgrade to unlock
Permanent Establishment (PE)
Premium content - upgrade to unlock
Tax Compliance and Reporting Requirements
Premium content - upgrade to unlock
Case Studies in International Taxation
Premium content - upgrade to unlock
Unit Outline 40h
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.
Study Materials
No notes yet
Notes will appear here once uploaded.
No questions yet
Practice questions will appear here.
Get Study Materials
CATs
Loading…
Assignments
Loading…
Exam Papers
Loading papers…