Tax Treaty & Transfer Pricing
Program for Brazil, Portugal,
Angola & Mozambique

March 2022   –   May 2022   

 

Sponsored by:

SILVER SPONSORS

 

 

 

General information

During the period March 2022 – May 2022 ITC Leiden will offer an online Tax Treaty & Transfer Pricing Program for Brazil, Portugal, Angola & Mozambique. It will be taught mostly in Portuguese.

Overview

The ITC Tax Treaty & Transfer Pricing 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 ITC Leiden’s 12-months Adv LLM Program:  the Tax Treaties course and the Basic & Advanced Transfer Pricing courses.

Each of the three courses of the Program is taught in ten days spread over a period of two and a half weeks, with classes (lectures and workshops) of three hours on each weekday except Wednesday.  The Program’s subjects are taught by teachers of ITC Leiden (incl. prof. Kees van Raad) and prominent Brazilian and Portuguese ITC alumni.  Most of the classes will be given in Portuguese, with a few in English (including prof. Kees van Raad’s classes).

Courses

The three courses (of ten days each, within a period of two and a half weeks) can be registered for individually or jointly (see further below, under ‘Course fees & discounts’).  The courses 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.  OECD Pillar One & Pillar Two – Blueprints and progress
5.A.  Brazilian CFC rules (Law 12,973/14)
5.B. For Portugal, Angola, Mozambique–the proposed EU Unshell Directive (ATAD3)
6.  Exchange of information
7.  Beneficial ownership and tax treaty anti-avoidance provisions
8.  Non-discrimination issues under tax treaties
9.  Brazil-Portugal-Angola-Mozambique: Cross-border investment & HNWI estate tax planning (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 the Course Overview with the individual subjects of the three Courses and the teachers.

Program organization

The Program is organized by:  Kees van Raad (ITC), Edgar Gomes (TAGD/Brazil)  [TBC: and Dinis Tracana (PLMJ/Portugal)].
>>  Coordinator of the Program is Edgar Gomes (to be reached at Brazil.Summercourse@itc-leiden.nl).

Sponsoring

Firms are invited to contact the Program Coordinator, Edgar Gomes (Brazil.Summercourse@itc-leiden.nl), for more information regarding the available sponsorship packages.

Course fees & discounts

Course Fee (exclusive VAT *)
For one course:                  BRL 3,000 or € 470
For any two courses:         BRL 5,500 or € 850
For three courses:              BRL 8,000 or € 1250
*  Applications are subject to 21% VAT unless made by a non-EU resident or by a (non-Dutch) EU resident with a VAT registration number.

–   Persons that register for Course B (Advanced Subjects) without having registered for Course C (Transfer Pricing), may attend free of charge the first class (Introduction to TP) of the Transfer Pricing course.
–   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.

Please note that we are not able to accept credit card payments in Brazilian Real (BRL).
Payments in BRL can only be done by bank transfer or by PayPal. 

Discounts
⧠  Associates of the IBDT, ABDF, Dutcham & GETI: a 10% discount applies. *
⧠  Teachers and students of the IBDT & Ibmec Rio: a 10% discount applies. *
⧠  ITC Adv LLM Alum nominees: a 15% discount applies. **
⧠  Group registration: Three or more persons that make a joint single payment of the overall tuition amount due please contact Brazil.SummerCourse@itc-leiden.nl
* Discount will only be accepted and applied if membership ID/documentation is provided and after verification by the institute concerned.
** Discount will only be accepted and applied upon receipt of email from an ITC alumni with the name of the nominee and confirmation of the nomination.

Please note that the various above discounts cannot be combined.  If you qualify for more than one discount, the larger one will be applied.  However, irrespective of the application of any of these above discounts, persons whose registration fee is received by 10 February 2022 qualify for the additional super early bird discount of 15%. And persons whose registration fee is received after 10 February 2022 but before 20 February 2022 qualify for the early bird discount of 10%.

Student discount
Up to five Master or PhD students are granted a 50% student discount on a first-pay-first-served basis. Students need to submit proof of registration from their University and a signed letter from their University or professor confirming their student status. Please note that students who obtain the 50% student discount are not entitled to any other discount.

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).

Periods [tentative] and hours of the three courses

–  Tax Treaties course:                 14 March – 29 March 2022
–  Advanced Subjects course:   31 March – 19 April 2022
–  Transfer Pricing course:          28 April – 13 May 2022

Class hours are each weekday except Wednesday at Dutch (= CET) time 13.00-16.00 h.  (from 27 march: summer time:
14.00-17.00 h). For Brazil, Portugal, Angola and Mozambique this corresponds with:
⧠   Brazil:  09.00 – 12.00                                                                   ⧠  Angola:  13.00 – 16.00
⧠   Portugal:  12.00 – 15.00 (from 27 march 13.00-16.00)        ⧠  Mozambique: 14.00 – 17.00

It is recommended that after class participants review that day’s lecture or workshop and prepare for the next class.

Executive Certificate

Those who attend at least 80% of the class hours will be issued by ITC Leiden a Certificate of Attendance.

Cancellation policy

–  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.

Further information

Please contact the Program Coordinator at Brazil.Summercourse@itc-leiden.nl.

Registration

The deadline for registration (at the course fees listed above):
–  the overall program or only the Tax Treaties course is:  8 March 2022,
–  for the Advanced Subjects course:  18 March 2022,
–  for the Transfer Pricing course: 8 April 2022

If you register later, you may need to make an additional payment for the individual mailing of the course book.

Please click here to register and pay in EUR.
Please click here to register and pay in BRL.