July 2022 Summer Course in International Tax Law coordinated and co-taught by Prof. dr. Kees van Raad
First week (Tax treaties)
4-8 July 2022
This week offers for those practitioners that – occasionally or frequently – deal with tax treaties a thorough knowledge of the complex rules that govern these treaties. It is virtually impossible to obtain a correct understanding of the rules on tax treaty interpretation and application without expert instruction in the far from obvious ways in which these rules operate. The instructors of this week are seasoned teachers of the ITC Leiden. They will introduce you to both the basic concepts and the fine points of the tax treaty rules.
• Key concepts of international tax law
• Introduction to tax treaties & treaty residence
• Business profits taxation under tax treaties
• Dividends, interest & royalties and immovable property income & capital gains under tax treaties
• Income from employment, pensions, etc. under tax treaties
Second week (Advanced subjects)
11-15 July 2022
For the truly experienced tax treaty expert the second week offers a series of interesting stand-alone subjects, each taught by specialists in the given area. The week opens with an in depth-analysis of complex tax treaty cases from international tax practice. It is followed by two days of advanced technical topics: double tax relief issues & non-discrimination, the principal purpose test (PPT) within the larger framework of measures countering tax treaty abuse, and the application of MLI-supplemented tax treaties. Next, the main lines of OECD Pillars One and Two will be explored with an updated outlook for their being put into effect. The week is concluded with a primer on transfer pricing: interesting for those who will not join the third week and a perfect introduction for those who will attend the Summer Course’s third week.
• Tax treaty interpretation and application illustrated with complex cases from international tax practice
• Double Taxation Relief & Non-Discrimination
• Treaty abuse and PPT; MLI and its application
• OECD Pillar One & Pillar Two – proposals and progress
• Transfer Pricing Issues – an introduction
Third week (Transfer pricing)
18-22 July 2022
• Introduction to the arm’s length principle and Traditional Transaction Methods
• Transactional profit methods
• Intra-group services and economic analysis
• Intangible property and Transfer pricing disputes
• Transfer pricing aspects of business restructurings and Cost Contribution Agreements
The course is planned to take place in the landmark building of the ITC located in the historical center of the city of Leiden.
As we do not know whether – and, if so, to what extent – live meetings and travel will be possible in July of this year, we are currently making arrangements to offer the course also online, either exclusively (if the situation in July would not permit international travel and group gatherings) or in addition to the actual classes that are held in the ITC building in Leiden. If the course is (also) available online (real time), participants in other time zones will be given the opportunity to login and view a recording of the class.
Daily course hours: 9:00-12:30 & 13:30-16:00 CET.
For a single week: € 2,000
For any two weeks: € 3,500
For three weeks: € 5,000
* All 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.
Course fees include reading materials and the following books:
– for participants First and Second weeks: Van Raad (ed.), Materials on International, TP & EU Tax Law, Vol. A [Int’l] (ITC, Leiden, approx. 2500 pp).
– for participants Third week: Van Raad (ed.), Materials on International, TP & EU Tax Law, Vol. B [TP] (ITC, Leiden, approx. 1900 pp).
The course fee does not include accommodation. For an information sheet on hotel accomodation in Leiden, please click here.
Application Deadline – deadline may be extended on request
The application deadline is 1 June 2022. To apply, please click here.
After the deadline has passed, please contact firstname.lastname@example.org to check whether you still may be able to register.
For further information: send a message to email@example.com with your name, and with subject `information requested´ outlining the extra information you require.
Cancellation more than one month before the beginning of the course: full refund minus € 250 cancellation fee.
Cancellation within one month: no refund but the person may be substituted: the registered person that is not able to come, may send another person in his/her place (and transfer both books).
(This information is subject to change, check this website on a regular basis).