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Course Overview This course is an introduction to structures underlying international corporate tax planning. The principles are illustrated throughout by examples drawn directly from experience. The course is intended for individuals with tax responsibility in groups that are considering or furthering international expansion. The course is of general application rather than dealing with the legislation of particular countries. Course Outline - The beginnings of international expansion, when a tax presence abroad has to be recognised
- The choice of the structure -branch or subsidiary
- The use of holding companies in structuring the expansion
- Financing the expansion -thin capitalisation rules
- Introduction to transfer pricing, the movements of products, intangibles and services
- Controlled foreign companies legislation
- Anti tax haven legislation
- The remittance of profits
- Corporate residence
- Double tax relief and tax treaties
- The impact of EU case law
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