This intensive legal training course focuses on how tax treaties are interpreted, applied, and leveraged to avoid double taxation in international transactions and investment planning. It prepares participants to work hands-on with bilateral tax treaties, model conventions (OECD, UN, U.S.), and relevant domestic law, while developing the practical skills necessary to structure transactions, resolve residency disputes, and optimize treaty benefits for multinational clients.
Designed for legal advisors, corporate counsel, tax professionals, and cross-border investors, the course offers practical exercises in treaty interpretation, benefit claims, and treaty override prevention, and provides transaction-focused guidance on tax-efficient structuring of foreign investment, services, and royalties.
Course Objectives
By the end of the course, participants will be able to:
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Interpret the key provisions of bilateral tax treaties using model conventions and case law.
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Apply treaty rules to real-world cross-border transactions and residency disputes.
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Identify and resolve potential conflicts between domestic law and treaty obligations.
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Structure investments and service arrangements to lawfully utilize treaty benefits.
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Prepare effective documentation and disclosures to support treaty-based positions.
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Navigate mutual agreement procedures (MAP) and competent authority negotiations.
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Analyze anti-avoidance rules (e.g., LOB, PPT, BEPS) and ensure treaty-compliant planning.
