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  Trends in International TaxationFOR MORE INSIGHT ON INTERNATIONAL TAXATIONFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More, PLEASE READ THIS ARTICLE: Introduction to International TaxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More: Key Concepts & Guidelines International TaxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, […]

This lecture will most likely be given by a guest lecturer who specializes in international tax structuring. The reading requirements are: 14 16 2018 Anti ­abuse legislation The Importance of Substance in a Private Equity Fund Context 14 16 anti-avoidance how robust is a Structured Finance Deal Read the double-dip leasing example in Chapter 1.4 of your Primer again – 1 Chapter Introduction on page 11 1

TRANSFER PRICINGTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulationsTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More, it governs how prices for goods, services, or intangibles (such as intellectual propertyIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit their work, ensuring protection against unauthorised use or reproduction. These rights are critical in fostering innovation and creativity while providing economic value to individuals and organisations. IP... More) are set when these items are exchanged between

All the assignment dates and the tutorial dates for submission of answers can be found on the Curriculum Spreadsheet: see for example:  http://iitfconnect.com/?p=1330 Any late assignments and tutorial answers submissions will NOT be marked. You will lose your points/marks.   ASSIGNMENTS The 3 assignments counts 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} each, ie. 30{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} towards the 100{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} course marks/points: Assignment 1 TP one source study assignment Here are

All the assignment dates and the tutorial dates for submission of answers can be found on the Curriculum Spreadsheet: see http://iitfconnect.com/?p=1327 Any late assignments and tutorial answers submissions will NOT be marked. You will lose your points/marks.   ASSIGNMENTS The 3 assignments counts 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} each, ie. 30{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} towards the 100{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} course marks/points: Assignments 2018 vr2 – 3 assignments.

Follow curriculum – Reading: International Tax Primer 3rd Edition Brian Arnold – eBook – Chapter 9 http://www.oecd.org/ctp/beps-2015-final-reports.htm – Action 1 – Digital economy; Action 2 – Hybrid mismatches; Action 5 – Harmful business practices; Action 14 – Dispute resolution   Additional supplementary reading – some required to answer tutorial questions: 22 23 2018 SARS’s stance on the tax

Follow curriculum – Reading: International Tax Primer 3rd Edition Brian Arnold – eBook – Chapter 8 OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More Income and Capital Model Convention and Commentary 2017 ARTICLES 1 to 4; 5 and 7; 6, 13 and 22; 11 and 12; 24; and 27; and commentaries UN Model Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... More Convention and Commentaries 2011 Update ARTICLES 1 to 4; 5

Pre-recorded lectures on anti-avoidance and CFCControlled Foreign Corporations (CFCsControlled Foreign Corporations (CFCs) are a fundamental concept in international taxation, referring to foreign companies that are under the control of domestic shareholders. Control is typically established when residents of a country, either individually or collectively, own more than a specified percentage of a foreign company’s shares, voting rights, or have the ability to exert substantial influence over its decision-making.... More) are a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More, referring to foreign companies that are under the control of domestic shareholders. Control is typically established when residents of a country, either individually or collectively, own more than a specified percentage of a foreign company’s shares, voting rights, or

Recorded lectures: IT Week 11 https://www.dropbox.com/sh/iu727klzf4v6sb8/AACgei3HKcByGfCDRR95vjRKa?dl=0 Lecture 11 Slides: https://www.dropbox.com/s/uaoc5gytqor4ijr/IT{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202018{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Lecture{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2011{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}28TP{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}231{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}29 IT Week 12 https://www.dropbox.com/sh/4z7rulixtsivpjx/AAA5_tPiMfrbsvRUE6_ilRsTa?dl=0   TP Week 15 https://www.dropbox.com/sh/v7urmo9vu9bx4i1/AABqDiu1S48Zog1ajCtmv5Tda?dl=0   Follow curriculum – Reading: International Tax Primer 3rd Edition Brian Arnold – eBook – Chapter 6 PWC International TP 2015-16 – read the introductory section prior to the country analyses, pages 3 to 182 http://www.oecd.org/ctp/beps-2015-final-reports.htm – Action 8-10

Lecture 9 & 10, with  instruction to submit a written memorandum based on the problem given in the lecture: https://www.dropbox.com/s/15a7fir87ql1dzs/IT{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Lecure{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}209{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20and{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2010{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20on{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20taxation{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20of{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20residents{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20and{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20non-residents_converted.mp4?dl=0 Here  is a diagram illustrating the problem set out in lecture 9 & 10: PPT Slide 6 Aug 2018 of problem for residents and non residents 9-10 DTAA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More Mauritius – South Africa – Double Tax