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Principles of Tax Treaties: Understanding the Application of Tax Treaties to Business Income

Expert Speaker Sivakumar Saravan

$1,200.00 (including GST)

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Overview

As businesses go global, it becomes essential for them to understand their cross-border tax exposure and how they can mitigate double taxation. With the contracting parties in different countries, the tax system of one country may differ from another, resulting in tax issues that need to be resolved through tax treaties.

This programme is part of the Corporate Practice Series, designed specifically to give Business Directors, Finance & Tax Professionals a practical understanding of the purpose of tax treaties, how business income is allocated under tax treaties and the key issues in interpreting and applying tax treaties. The Trainer will also analyse specific definitions and articles of the OECD and the UN Model Tax Conventions to explain what they mean, how they work, the benefits as well as the pitfalls to avoid. 

What You Will Learn

At the end of this workshop, you will:

  • Have a practical understanding of how tax treaties work in mitigating double taxation
  • Have a good understanding of Permanent Establishment and the practical issues revolving it
  • Be more confident in using tax treaties to manage cross-border tax exposure
  • Know the current global developments that will have an impact on the use and interpretation of tax treaties

Programme Outline

DAY ONE

Understanding Tax Treaties

  • Purpose of tax treaties
  • Types of tax treaties
  • Model Conventions: OECD Model, UN Model
  • Structure of tax treaties
  • Basic principles of tax treaties
  • Scope of tax treaties
  • General definitions article
  • Step-by-step guide to applying the tax treaty provisions

Income Allocation Rules

  • Types of income allocation rules
  • Applying the income allocation rules

Permanent Establishment

  • Analysis of Article 5(1) of the OECD Model Convention
  • Types of PE & exceptions to the PE
  • Analysis of Article 5(3) of the OECD Model Convention
  • Analysis of Article 5(5) & 5(6)of the OECD Model Convention
  • Implications of BEPS Action Plan 7

The Business Profits Article

  • Meaning of “Business Profits”
  • Meaning of “carrying on a business”
  • Profit attribution to a PE
  • "Business Profits" Article vs "Other Income" Article
  • How to apply the Business Profits Article

Service Income and the Business Profits Article

  • Articles dealing with services
  • When can the Business Profits Article be used?
  • OECD vs UN Model Convention
  • Interpretation of Service PE
  • Interactions between Service PE and other provisions of Article 5
  • Typical PE issues

DAY TWO

Fee for Technical Services 

  • Interpreting the 'Technical Services' Article
  • Meaning of “managerial, technical or consultancy”
  • “Beneficial ownership” requirement
  • Comparison of Singapore’s tax treaties with India & Malaysia
  • Recent case law on the interpretation of 'Fee for technical services'

Independent Personal Services

  • Scope of this article
  • Meaning of “fixed base”
  • UN Model vs OECD Model Convention

Dividends, Interest and Royalties

  • Income characterization
  • Conditions for claiming reduced withholding tax rates
  • Other considerations

Other Income

  • Rental
  • Capital gains

Claiming Tax Credits under Tax Treaties

  • Tax credit mechanism
  • Conditions for claiming foreign tax credits
  • Tax sparing credits
  • Tax residency issues

Anti-avoidance Measures

  • General anti-tax avoidance measures
  • Specific anti-tax avoidance measures
  • BEPS developments

Expert Speaker

Sivakumar Saravan, Executive Director, Tax and Corporate Advisory, Crowe Horwath Singapore has about 20 years of experience in tax compliance and tax consultancy work for individuals as well as local corporations, multinationals and financial institutions. Siva is a member of Crowe Horwath's International Tax Committee and he has conducted several seminars on international tax to Crowe Horwath tax specialists in the Asia Pacific region as well as to members of the public. He is the author of CCH’s Singapore Withholding Tax And Treaties Online, Crowe Horwath’s Quick Guide to Business Tax in Singapore and Tax Essentials for HR Professionals’.  He is the consultant editor of CCH's Singapore Master Tax Guide manual. Siva is an accredited tax advisor of the Singapore Institute of Accredited Tax Professionals. He is also a member of The Institute of Singapore Chartered Accountants of Singapore and the Singapore Institute of Arbitrators.

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