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ITA101 Fundamentals of Tax Treaties - Lesson 2b (11:30/26:49)
Outline
Thumbnails
Narration
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How tax treaties operate
Allocating taxing rights under the treaty
Lesson overview
Residence State
Royalties taxation under domestic law
Royalties – treaty allocation of taxing rights
Source State
Allocating taxing rights under the treaty
Royalties – treaty allocation of taxing rights
Royalties – treaty allocation of taxing rights
Income from
immovable property
Interest – taxation under domestic law
Interest – treaty allocation of taxing rights
Interest – treaty allocation of taxing rights
RENT
Interest – treaty allocation of taxing rights
Income from immovable property – domestic
Income from immovable property – domestic
May tax
Income from immovable property – domestic
Allocating taxing rights under the treaty
Treaty allocation rules - comparison
Categories of income in the OECD Model
Treaty allocation rules
Source state thresholds
OECD
May tax
OECD Model Tax Convention on Income and on Capital
Art. 6
INCOME FROM IMMOVABLE PROPERTY
(1) Income derived by a resident of a Contracting State from immovable property
(including income from agriculture or forestry) situated in the other Contracting State may
be taxed in that other State.
Source state thresholds
Source state thresholds
Source state thresholds
Employment income threshold
Business profit threshold
Business profit threshold
Permanent establishment
© 2009 IBFD International Tax Academy
Overview of the OECD Model Convention
SLIDE 16 OF 32
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Tax Treaties
„„ ITA101 Fundamentals of Tax
„„
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2
Treaties
ITA102 Residence
ITA103 Permanent
Establishments
ITA104 Employment and Related
Income
ITA105 Passive Income
ITA106 Business Profits
Transfer Pricing
„„ ITA Online Transfer Pricing Study
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„„ ITA107 Fundamentals of Value
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ITA101 Fundamentals of Tax Treaties
Welcome
core lessons. Following their order, you will be
guided through the course in an organized and
logical fashion.
„„ Additional optional lessons (highlighted in light
blue) cover specialized topics to expand your
knowledge in the subject areas.
„„ To facilitate your learning, print a handout of
each audio lesson. This will help you take
effective notes during the course and
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Lessons
(1) The international tax environment
International Tax Academy ONLINE
„„ Each course comprises sequentially displayed
(1) The international tax
enviroment
- Domestic law as the foundation of international tax
- Features with cross-border impact
- Overview of international tax environment
- Introduction to key concepts
(2a) Double taxation relief
Core study time: 55 min
(2b) How tax treaties
operate
(3) Revision quiz 1
Audio Lesson
Lesson 1: Audio Lesson
(A handout is available for you to print and make notes while following the audio lesson.
Click here for the handout.)
Study time: 30 min
Play audio lesson
(4) Role and development
of model treaties
Glossary
Revise key terms
Revise key terms covered in this lesson. For each term you
can look up a definition in the IBFD International Tax Glossary.
(5a) The making of tax
treaties
Click here
(5b)Eligibility to treaty
benefits
Study time: 20 min
(6) Revision quiz 2
Handout
Conceptual map of factors influencing the international tax environment
View/print a conceptual map of the international tax environment, consisting of three levels.
Click here
(7a) Case studies
(7b) Interpretation and
dispute resolution
(8a) Policy considerations
(8b) Expert comment
Expert Comment
Interview with Michael Lennard (Part 1)
This is the first part of an interview between Joanna Wheeler and Michael Lennard where he talks
about international organizations active in the area of international tax law and their aims in this respect.
Study time: 5 min
Click here
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ITA101 Fundamentals of Tax Treaties - Lesson 2b (11:30/26:49)
Outline
Thumbnails
Narration
Search
How tax treaties operate
Allocating taxing rights under the treaty
Lesson overview
Residence State
Royalties taxation under domestic law
Royalties – treaty allocation of taxing rights
Source State
Allocating taxing rights under the treaty
Royalties – treaty allocation of taxing rights
Royalties – treaty allocation of taxing rights
Income from
immovable property
Interest – taxation under domestic law
Interest – treaty allocation of taxing rights
Interest – treaty allocation of taxing rights
RENT
Interest – treaty allocation of taxing rights
Income from immovable property – domestic
Separate tabs enable you to view each
lesson’s outline or miniature slides, follow
word-for-word narration of the audio, and
search for a particular phrase in the lesson
you may want to review.
Income from immovable property – domestic
May tax
Income from immovable property – domestic
Allocating taxing rights under the treaty
OECD
Categories of income in the OECD Model
Art. 6
INCOME FROM IMMOVABLE PROPERTY
Treaty allocation rules
Source state thresholds
May tax
OECD Model Tax Convention on Income and on Capital
Treaty allocation rules - comparison
(1) Income derived by a resident of a Contracting State from immovable property
(including income from agriculture or forestry) situated in the other Contracting State may
be taxed in that other State.
Source state thresholds
Source state thresholds
Source state thresholds
Employment income threshold
Business profit threshold
Business profit threshold
Permanent establishment
© 2009 IBFD International Tax Academy
Overview of the OECD Model Convention
SLIDE 16 OF 32
Self-study directs you to supplementary
reading materials to further develop your
understanding of the course topics.
Access relevant excerpts from the OECD
and UN Model Tax Conventions, related
Commentaries, court cases, or other
applicable IBFD publications with just one
click on the link and avoid
time-consuming searches.
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Self Study
Articles 23A and 23B of the OECD Model
In the OECD Model, there are two alternatives for the article on double tax relief. Art. 23 A is
written for states that mainly use the exemption method, and Art. 23B is written for states that
mainly use the credit method.
Articles 23A and 23B of the OECD Model
Source: IBFD Tax Treaties Database
Click here
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