Tax Treaties

This Module 2 Tax Treaties offers a theoretical and practical approach to understanding tax treaties, cross-border tax planning strategies, international tax dispute resolution mechanisms, and international tax compliance.

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Students will begin with fundamental concepts of international taxation, including international double taxation (namely credit method, exemption method, juridical and economic double taxation, etc.), OECD and UN model tax treaties, and key treaty interpretation principles. The curriculum also covers business income with a strong focus on the taxation of a permanent establishment, passive income, employment taxation, hybrid entities, attribution of profit in various jurisdictions, etc.

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Advanced modules cover international tax avoidance, GAAR, beneficial ownership, and the principal purpose test (“PPT”). Students will also learn how to structure international business transactions, allocate taxing rights, and navigate cross-border M&A from a tax perspective. The course includes real-world case studies on triangular cases, exchange of information, and tax dispute resolution mechanisms to ensure the practical application of tax treaty concepts.

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After completing this Module, students will have gained:

• A deep understanding of tax treaty application and interpretation.

• Expertise in cross-border taxation, dispute resolution, and tax litigation.

• Skills in international tax planning, structuring investments, and tax-efficient corporate strategies.

• The ability to navigate BEPS, global minimum tax rules, and transfer pricing implications.