Jacques Sasseville, yang merupakan:
- Guest Lecture di International Taxation Program, University of Leiden and Vienna University
- Head of Tax Treaty Unit, OECD (1995-2016)
- Inter-Regional Advisor, United Nation
Isu-isu yang akan dibahas dari hari pertama hingga hari terakhir dirincikan sebagai berikut:
Senin, 5 November 2018
Introduction:
– The changing international tax environment
– Role and basic structure of tax treaties
– History of UN and OECD Models
– Legal status of the UN and OECD Models
– Impact on tax treaties of the G20/OECD BEPS Action Plan
– Current work related to the UN and OECD Models
Selasa, 6 November 2018
Analysis of the standard provisions of tax treaties
– Persons entitled to treaty benefits
Tax treaty residence
Rules on entitlement to treaty benefits
Concept of tax treaty residence
– Taxation of business profits
Overview of the applicable treaty rules
Concepts of enterprise, business profits and permanent establishment
Attribution of profits to permanent establishments
Rabu, 7 November 2018
Analysis of the standard provisions of tax treaties (cont.)
– Taxation of business profits (cont.)
Business profits dealt with in other articles
Conflict rules
Income from the operation of ships and aircraft in international traffic
Fees for technical services
– Taxation of income from immovable property
– Taxation of capital gains
– Taxation of dividends
– Taxation of interest
– Taxation of royalties
Cases
Kamis, 8 November 2018
Analysis of the standard provisions of tax treaties (cont.)
– Taxation of income from professional services
– Taxation of employment income
– Taxation of directors' fees and remuneration of top-level officals
– Taxation of income of entertainers and sportspersons
– Taxation of pensions and social security payments
– Taxation of income from government services
– Taxation of payments to students and teachers
Jumat, 9 November 2018
Analysis of the standard provisions of tax treaties (cont.)
– Methods for elimination of double taxation
– Non-discrimination
– Mutual agreement procedure
– Administrative assistance
Interpretation of tax treaties
Improper use of tax treaties
Sabtu, 10 November 2018
Court decisions related to the interpretation
and application of tax treaties
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