The course will address the following topics:
- Introduction to the concepts of jurisdiction to tax, double taxation, double non-taxation
- Scope of Tax Treaties
- Allocation rules part 1 (Art 7 and 9 OECD Model Convention)
- Allocation rules part 2 (Art. 10 to 12 OECD Model Convention)
- Allocation rules part 3 (Art. 15 to 20 OECD Model Convention)
- Methods of elimination of double taxation
- Anti-avoidance measures