Courses

• An Overview of International Taxation
  
  1. What is International Taxation?
  2. International Tax Conflict and Double Taxation
  3. Double Tax Treaties
  4. Domestic Tax System
  5. International Offshore Financial Centers
  6. Anti-avoidance Measures
  7. International Tax Planning
  8. Non-Resident Taxation in Pakistan

• Principle of International Taxation
  
  1. International Tax Law
  2. Application of Tax Treaties
  3. Interpretation of Tax Treaties
  4. Some Legal Decisions on Treaty Interpretations
  5. Model Tax Conventions
  6. Multilateral Tax Agreements
  7. European Union
  8. Harmful Tax Competition

• Model Tax Conventions on Double Tax Avoidance
  
  1. OECD Model Convention on Income and Capital (OECD MC)
  2. UN Model Convention (UN MC)
  3. US Model Convention (US MC)
  4. Articles in the Model Conventions
  5. Bilateral Tax Treaties

• Impact of Domestic Tax Systems
  
  1. Introduction
  2. Tax Residence or Fiscal Domicile
  3. Source of Income or Gain
  4. Basis of Tax Computation
  5. Treatment of Tax Losses
  6. Advance Tax Rulings
  7. Passive Income
  8. Foreign Tax Relief

• Transfer Pricing and Thin Capitalization Rules
  
  1. Introduction
  2. What are Transfer pricing issues?
  3. What is Transfer Pricing?
  4. Meaning of the term “arm’s length Principle”
  5. Significance of arm’s length principle
  6. Practical difficulties in application of ALP
  7. Evolution of Transfer Pricing
  8. Computation of income from transaction with non-resident
  9. Associated Enterprises
  10. International Transaction
  11. Specified domestic transactions
  12. Computation of Arm’s length price
  13. Functions, assets and risk (Far Analysis)
  14. Concepts of Comparability adjustments
  15. Documentation and Compliances
  16. Specific reporting requirements- Country by Country reporting
  17. Transfer Pricing Assessments
  18. Transfer of Income to Non- residents
  19. Introduction of specific anti avoidance measures in respect of transactions with person located in notified jurisdictional area
  20. Limitation of interest deduction in certain cases

• International Tax Avoidance
  
  1. Base erosin and profit shifting

• Other Related Studies
  
  1. Background
  2. Overview of BEPS
  3. Addressing the tax challenges of the digital economy
  4. Neutralise the effects of hybrid mismatch arrangements
  5. Strengthen controlled foreign companies (CFC) Rules
  6. Interest deductions and other financial payments
  7. Counter harmful tax practices
  8. Preventing treaty abuse
  9. Prevent the artificial avoidance of permanent establishments (PE) status
  10. Transfer pricing outcomes in line with value creation/intangibles/risk and capital and other high-risk transactions
  11. Measuring and monitoring BEPS
  12. Disclosure of aggressive tax planning arrangements
  13. Re-examine transfer pricing documentation
  14. Making dispute resolution more effective
  15. Developing a multilateral instrument

• 02 Months
• From 01 st May to 30 th June
• University Students & Fresh Graduates

25,000/ to 3 5000/

Advanced Certificate in Taxation is structured for those who are keen to learn
technical concepts in local and international taxation. The certificate covers three
key aspects of taxation i.e. e., Direct Taxes, Indirect Taxes, and I nternational Taxation.
It focuses on technical concepts of direct and indirect taxes and develops an
understanding of various components involved in the determination of income tax
while dealing internationally. For Secondary jurisdictions GCC, UK, Canada &
USA are available on choice, however, a student may select any other tax jurisdiction
with the prior approval of the Students Members Committee