2020 ITC Online Exec Program
in International Tax Law —
for Brazil, Portugal & Angola
December 2020 – February 2021
During the period December 2020 – February 2021 ITC Leiden will offer for the first time in Brazil an ONLINE Executive Program on International Tax Law program for Brazil, Portugal and Angola. It will be taught mostly in Portuguese.
The ITC Online Executive Program is targeted at tax professionals in Portuguese-speaking countries who typically work in private practice, with the government, or in a company’s tax department and who want to expand their knowledge and understanding of international tax law. The Program comprises three courses (Tax treaties, Advanced subjects, Transfer pricing) that feature the essentials of the main courses of the 12-months ITC Leiden’s Adv LLM Program: i.e., the Tax Treaties course and the Basic & Advanced Transfer Pricing courses.
Each of the three courses of the Program is taught during a period of two weeks with classes (lectures and workshops) of three hours each day (Monday-Friday). The Program’s subjects are taught by teachers of ITC Leiden (incl. prof. dr. Kees van Raad) and prominent Brazilian ITC alumni. Most of the classes will be given in Portuguese, with a few in English (including Prof. Kees van Raad).
The three courses (of two weeks each) of the Program can be registered for individually or jointly. They cover the following topics:
A. Tax Treaty course
1. Key concepts of international tax law (2 days)
2. Introduction to tax treaties and treaty residence (2 days)
3. Business profits taxation under tax treaties (2 days)
4. Dividends, interests & royalties and immovable property income & capital gains under tax treaties (2 days)
5. Income from employment, pensions, etc. under tax treaties (2 days)
B. Advanced Subjects course
1. Tax treaty interpretation and application illustrated with complex cases from international tax practice
2. Taxation of technical services
3. BEPS and the OECD/G20 Multilateral Instrument
4. Brazilian CFC rules (Law 12,973/14)
5. Beneficial ownership and tax treaty anti-avoidance provisions
6. Exchange of information
7. OECD Blueprint for Pillar One & Pillar Two
8. Non-discrimination issues under tax treaties
9. Cross-border investment: Brazil – Portugal – Angola (2 days)
C. Transfer Pricing course
1. Introduction to TP
2. Comparability analysis
3. Transfer pricing methods (2 days)
4. Intra-group services & Cost Contribution Arrangements (CCAs)
5. Financial transactions
6. Business restructurings and intangibles (2 days)
7. Digital economy
8. Future challenges to TP
Click here for a 4-page Course Overview with the individual subjects of the three Courses and the teachers.
The Program is organized by a committee comprising: Kees van Raad (ITC), Edgar Gomes (Terciotti), Alexandre Siciliano (Lobo de Rizzo), Ana Carolina Monguilod (PG Law), Dinis Tracana (PLMJ/Portugal) and José Guerra (CCSL/Portugal, Angola).
>> Coordinator of the Program is Edgar Gomes (to be reached at Brazil.Summercourse@itc-leiden.nl).
Firms are invited to check with Program Coordinator Edgar Gomes (at Brazil.Summercourse@itc-leiden.nl) for interesting registration/sponsoring arrangements.
Course fee & discounts
The tuition fee for the three courses combined amounts to: BRL 8,000 or € 1220
For the individual courses the tuition fee amounts are:
⧠ Course 1 (Tax treaties) BRL 3,000 or € 460
⧠ Course 2 (Advanced subjects)* BRL 3,000 or € 460
⧠ Course 3 (Transfer pricing) BRL 3,000 or € 460
* Persons that take this course without having registered for the Transfer Pricing course, may attend free of charge the first class of the Transfer Pricing course (Introduction to TP)
It is possible to have within a single course participants alternate, i.e. one person participating in e.g. the first six days of a given course while another person participates in the remaining four days (but extra copies of the book need to be paid for).
Reader and book
The tuition fee for the first two Courses includes a reader for the given course, plus the following book:
⧠ Van Raad (ed.), Vol. A (International Tax Law, 2700 pages) of: Materials on International, TP & EU Tax Law (ITC Leiden).
Participants registering for the third Course receive the reader for that course, plus:
⧠ Van Raad (ed.), Vol. B (TP Tax Law, 1900 pages) of: Materials on International, TP & EU Tax Law (ITC Leiden).
⧠ Two-course discount: Persons registering for two courses receive a 10% discount.
⧠ Group registration: Groups of three or more persons that make a joint single payment of the overall tuition amount due: 10% discount.
⧠ Previous years’ students: Students that have already attended any of the individual weeks in previous editions of the Program (2016, 2017, 2018): 20%.
⧠ Associates of the IBDT, ABDF and GETI: a 10% discount applies.
⧠ Teachers and students of the IBDT: a 10% discount applies.
Please note that the various above discounts cannot be combined. If you qualify for more than one discount, the greater one will be applied. However, irrespective of the application of any of these above discounts, persons whose registration fee is received before 10 November 2020 qualify for an additional overall discount of 10%.
Period and hours of the three courses
– Tax Treaties course: 7 – 18 December 2020
– Advanced Subjects course: 18 – 29 January 2021
– Transfer Pricing course: 1 – 12 February 2021
Class hours are daily (Monday through Friday) at Dutch (afternoon) time 13.00-16.00 h. For Brazil, Portugal and Angola this corresponds (in the period December-February) with:
⧠ Brazil: 09.00 – 12.00
⧠ Portugal: 12.00 – 15.00
⧠ Angola: 13.00 – 16.00
It is recommended that participants use part of the afternoons and evenings for reviewing that day’s class and preparing for the next day’s class.
Those who attend at least 80% of the class hours will be issued by ITC Leiden a Certificate of Attendance.
– Cancellation more than 30 days before the first class of the course: full refund minus a cancellation fee of BRL 500 (€ 80)
– Cancellation within 30 days after the Program start: no refund but another person may be substituted for the person registered.
Please contact the Program Coordinator at Brazil.Summercourse@itc-leiden.nl.
The deadline for registration (at the course fees listed above):
– the overall program or only the Tax Treaties course is: 15 November 2020
– for the Advanced Subjects course: 28 December 2020,
– for the Transfer Pricing course: 11 January 2021
Later registration is possible, but you may need to make an additional payment for the individual mailing to you of the course book.
Click here to open the registration form with the tuition fees in Brazilian Real.
Click here to open the registration form with the tuition fees in Euros.
>> If you have any questions or if there are any issues with the registration form, please contact Brazil.Summercourse@itc-leiden.nl.