This intermediate-level course gives you the confidence and practical understanding you need in the field of international tax planning for multinational enterprises. The course is aimed at analysing the fundamentals of international tax planning in a structured and consistent manner, deepening the knowledge of tax planning techniques of the participants, and has been developed for executives with taxation knowledge, and tax professionals who do have specific international tax planning experience. Although the course will focus on practical cases, domestic legislation will not be addressed in specific detail.

This is an interactive course with a maximum of 30 participants. Prior to the course, participants will be given access to an online platform which provides them with additional pre-reading material and supplementary material (e.g. legal documentation, case law and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.

Day 1


08.30 - 09.00 Registration

09.00 - 09.20 Welcome and IBFD Overview

09.20 - 10.40 Key Concepts in International Tax Planning
and Anti-Avoidance Rules

• Fundamentals of international tax planning
• Tax planning, tax avoidance and tax evasion
• Goals and objectives of international tax planning
• Types of international tax planning
• Domestic and treaty anti-avoidance rules
• Other means to protect the taxable base

10.40 - 11.00 Break - Refreshments

11.00 - 12.45 Key Concepts in International Tax Planning
and Anti-Avoidance Rules (continued)

12.45 - 14.00 Lunch

14.00 - 15.20 Tax Planning for Holding Activities

• Goals and objectives of a holding company
• Selection of a holding company location
• Use of holding companies
• Taxation of dividends and capital gains
• Withholding taxes
• Overview of holding companies locations

15.20 - 15.40 Break - Refreshments

15.40 - 17.00 Tax Planning for Holding Activities (continued)











Day 2


09.00 - 10.20 Tax Planning for Financing Activities

• How financing arrangements affect group’s tax position
• Use of intra-group financing companies
• Use of hybrid financing models
• Other techniques

10.20 - 10.40 Break - Refreshments

10.40 - 11.40 Tax Planning for Financing Activities (continued)

11.40 - 12.45 Tax Planning for Manufacturing Activities

• Introduction
• The development of alternative forms of manufacturing
• Contract and toll manufacturing within a group
• Arm’s length pricing for contract and toll manufacturing
• Transitional issues

12.45 - 14.00 Lunch

14.00 - 14.40 Tax Planning for Manufacturing Activities (continued)

14.40 - 15.25 Tax Planning for Selling Activities

• Introduction
• Conventional distribution models
• Limited risk distributorships
• Commissionaires
• Arm’s length pricing
• Transitional issues

15.25 - 15.45 Break – Refreshments

15.45 - 17.00 Tax Planning for R&D Activities

• The creation of intellectual property
• Main tax issues
• Domestic incentives for the creation of intellectual property
• The management of intellectual property
• The migration of intellectual property

René Matteotti, Homburger, Switzerland
Harry Tonino, IBFD, the Netherlands
Mario Petriccione, KPMG, United Kingdom