International Taxation: Principles and Anti-Avoidance

Tax and Revenue Management October 25, 2025
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Introduction

This comprehensive course explores the complex world of international taxation, focusing on fundamental principles and the rapidly evolving anti-avoidance landscape. Participants will gain deep understanding of cross-border tax concepts, treaty applications, and the global initiatives shaping modern international tax rules. The curriculum covers both theoretical frameworks and practical applications, with special emphasis on BEPS initiatives, anti-avoidance legislation, and compliance requirements for multinational enterprises. Through detailed case studies and interactive discussions, attendees will develop the expertise needed to navigate this dynamic field.

Objectives

Upon completion, participants will be able to:

  • Understand core principles of international taxation
  • Apply double tax treaties effectively
  • Navigate BEPS action plan requirements
  • Implement anti-avoidance compliance measures
  • Manage permanent establishment risks
  • Structure cross-border transactions compliantly
  • Handle transfer pricing documentation
  • Evaluate tax treaty benefits and limitations
  • Manage country-by-country reporting

Target Audience

  • International tax directors and managers
  • Multinational corporation tax staff
  • Tax advisors and consultants
  • Government tax officials
  • Accounting firm international tax specialists
  • In-house counsel for global companies
  • Corporate development professionals
  • Tax technology specialists

Methodology

  • International case studies
  • Treaty interpretation exercises
  • BEPS implementation workshops
  • Cross-border scenario analysis
  • Group policy discussions
  • Regulatory update sessions
  • Country comparison exercises
  • Expert guest lectures

Personal Impact

  • Enhanced global tax perspective
  • Advanced technical expertise
  • Improved strategic analysis skills
  • Expanded international network
  • Career specialization opportunities
  • Continuing professional development

Organizational Impact

  • Improved global tax compliance
  • Reduced cross-border tax risks
  • Enhanced reputation with tax authorities
  • Better strategic decision-making
  • Optimized global tax positions
  • Strengthened governance framework

Course Outline

International Tax Fundamentals

Core Principles and Concepts
  • Source versus residence taxation
  • Jurisdictional taxing rights
  • Double taxation mechanisms
  • Tax treaty objectives and structures
  • Historical development of international tax
Tax Treaty Application
  • OECD Model Convention analysis
  • Treaty interpretation principles
  • Permanent establishment definitions
  • Withholding tax reductions

Anti-Avoidance Framework

General Anti-Avoidance Rules
  • GAAR principles and applications
  • Specific anti-avoidance rules
  • Substance over form doctrines
  • Business purpose requirements
  • Economic substance tests
Treaty Anti-Abuse Provisions
  • Limitation on Benefits clauses
  • Principal Purpose Test applications
  • Treaty shopping prevention
  • Hybrid mismatch rules

BEPS Implementation

BEPS Action Plan Overview
  • 15-action item summary
  • Minimum standards implementation
  • Country adoption variations
  • Multilateral Instrument impact
Key BEPS Actions
  • Action 5: Harmful tax practices
  • Action 6: Treaty abuse prevention
  • Action 7: Permanent establishment changes
  • Action 13: Transfer pricing documentation

Transfer Pricing Compliance

Documentation Requirements
  • Master file preparation
  • Local file specifications
  • Country-by-country reporting
  • Benchmarking studies and analysis
Risk Assessment
  • Risk identification methodologies
  • Audit exposure evaluation
  • Penalty risk assessment
  • Dispute resolution planning

Digital Economy Taxation

Emerging Challenges
  • Digital services taxes
  • Significant economic presence rules
  • Data and user participation concepts
  • Automated digital services taxation
Pillar One and Two Implementation
  • Amount A and B calculations
  • Global anti-base erosion rules
  • Income inclusion mechanisms
  • Undertaxed payments rules

Compliance and Risk Management

Multinational Compliance
  • Cross-border filing coordination
  • Information reporting obligations
  • Controlled foreign corporation rules
  • Foreign tax credit computations
Strategic Planning
  • Legal structure optimization
  • Supply chain restructuring
  • Intellectual property planning
  • Risk management frameworks

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