COURSE OUTLINE

• The problem of double taxation

• State practice in the conclusion of DTCs

• The effects of DTCs

• The interpretation of double taxation conventions

• Treaty abuse

• The structure and system of DTCs

• Persons covered

• Taxes covered

• Allocation rules

• Methods for elimination of double taxation

• Non-discrimination

• Mutual agreement procedure. Exchange of information. Assistance in the collection of taxes

- To familiarize you with Double Taxation Conventions as primary sources of international tax law and the different concepts used in international taxation;
- To explore the circumstances that lead to double taxation and the methods used to eliminate it;
- To gain a better understanding of how Double Taxation Conventions are drafted, and their scope of application (both personal and substantive);
- To work with the allocation rules and the "method article" provisions contained in the Double Taxation Conventions concluded between states.