Detailed event descriptions:
1. Comprehensive Tax Treaties
The Comprehensive Tax Treaties seminar provides an introduction to tax treaties and international taxation. It gives tax officials who have had little exposure to tax treaties and international taxation a foundation for understanding international tax concepts and applying tax treaties. The seminar examines all of the articles commonly found in tax treaties through a combination of lectures and discussion of case studies and illustrations. Participants will be introduced to the structure of tax treaties and the resources for interpreting them through exposure to the OECD Model Tax Convention and its Commentaries as well as the UN Model Double Taxation Convention.
Target Audience: Tax officials who have had little exposure to tax treaties and international taxation.
2. Advanced Application of Tax Treaties
The Advanced Application of Tax Treaties seminar is an advanced version of the OECD’s popular Tax Treaties Special Issues seminar that examines a smaller number of important tax treaty issues in much greater depth. It provides participants who have a good understanding of the application of tax treaties with an opportunity to discuss in detail relatively complex practical tax treaty application, interpretation and policy issues. The facilitators provide short lectures and guide the discussions of issues raised in case studies and court decisions. Participants are expected to be actively engaged in the discussions. The topics covered typically include the taxation of business profits, the permanent establishment definition, royalties, the taxation of foreign employees, the meaning of beneficial ownership, the treatment of non-corporate entities, treaty interpretation and international tax avoidance and treaty abuse.
Target Audience: Participants must have a good understanding of how tax treaties are applied and preferably will have previously attended either the Comprehensive or Special Issues Tax Treaty seminar. The seminar is intended to be especially useful for senior officials who are, or will be, involved with the application of tax treaties, consideration of competent authority issues and the negotiation of tax treaties for their country.
3. Negotiation of Tax Treaties (also for OECD-UN Joint Event)
The Treaty Negotiation Workshop is a very comprehensive and practical workshop from which many of today’s tax treaty negotiators have graduated. The main purpose of the workshop is to provide practical tax treaty negotiation experience as well as an understanding of the policy issues and technical problems frequently encountered in negotiations. The instructors include experienced treaty negotiators from OECD and NOE countries.
The workshop primarily takes the form of a simulated negotiation of all of the provisions of a bilateral double tax agreement between two fictitious countries. The negotiations are based on the fictitious countries’ treaty models, their recent treaties and descriptions of their domestic tax legislation. Participants are divided into four or six teams of up to five persons who negotiate the positions of their assigned country throughout the week. One instructor acts as the technical advisor for each team. Participants are expected to head the actual negotiations of each provision and each participant is expected to head the discussion of two or three articles during the week. Instructors assist each team’s preparation for the negotiation and provide guidance and feedback during the workshop. The simulated negotiations are supplemented with a series of short presentations and discussions on all aspects of tax treaty negotiations, including the organisation of a treaty negotiation programme, conducting negotiations and advice on strategies for successful outcomes.
Participants get from this workshop what they put into it. Preparation and active participation are essential. Participants should therefore be genuinely interested in learning how to negotiate tax treaties and be prepared for a challenging five days of intensive study and work. Assignments must be completed each night of the workshop to prepare for the next day’s negotiations. Despite all of the hard work, participants generally find the workshop stimulating and rewarding.
Because of the high resource cost in delivery, this event can only be run on limited occasions.
Target Audience:This workshop is especially useful for officials who are, or will be, involved with the negotiation of tax treaties for their country. It is essential that participants have a good command of the language adopted for the workshop, as they are expected to contribute actively in the preparation for the simulated negotiations and to take part in the negotiations themselves. Participants must also have a good understanding of the provisions of a tax treaty and will be expected to have familiarised themselves with the course material prior to the workshop. This workshop is NOT recommended for participants who are unfamiliar with the provisions of tax treaties.
4. Taxation of Non-Residents
Countries throughout the world are interested in attracting human and investment capital from abroad to improve productivity and economic growth. Much of this activity is undertaken by non-residents, including permanent establishments. This workshop focuses on the major policy and administrative issues unique to the taxation of income earned by non-residents. Key issues addressed are the definition of non-residents, common statutory source rules, anti-abuse rules and special administrative rules for non-residents. We will also look closely at the recent treaty developments in defining and attributing profit to permanent establishments. All topics are illustrated through case studies to ensure the course is of practical use to the participants. Time is also set aside to discuss country specific problems in the taxation of non-residents.
Target Audience: Officials from Ministries of Finance and Tax Administrations who have responsibility for treaties and the taxation of non-residents.
5. Tax Policy Analysis
The workshop on tax policy analysis discusses the tax policy criteria that help designing pro-growth and efficient as well as fair tax systems that reduce compliance costs for taxpayers, raise sufficient revenue and are simple to administer and enforce. The tax policy criteria will be applied to a number of topics of interest to senior tax policy makers. The topics considered in this workshop will evolve from year to year, at least in part, to cover tax policy areas of current and particular interest to OECD and non-OECD countries alike. For example, the workshop could focus on the following areas: i) linkages between taxation (mainly corporate income tax) and domestic and foreign direct investment; ii) taxation and innovation; iii) environmental (or „green‟) tax reforms; iv) taxation and savings; v) taxation and employment as well as skills formation; vi) taxation and the financial crisis; vii) pro-economic growth tax reform; viii) strategies that allow making fundamental tax reform happen; ix) tax and inequality; x) tax and informality. The workshop will also focus on the most recent tax policy trends, reforms and challenges in OECD and non-OECD countries as well as on tax indicators and models that are typically applied to assess tax policy. Participants are encouraged to draw to the attention of the workshop organizers other tax policy issues which are of particular interest to their country and which they would like to see covered during the workshop. Case study analysis and presentations are also encouraged.
Target Audience: senior tax policy makers who are actively involved in debating and designing tax policies in their countries.
6. Tax Expenditures and Tax Incentives
Most countries use tax incentives to attract investment and promote economic activity. It is essential that countries adopt a coherent approach to tax incentives to ensure that the benefits of tax incentives outweigh the costs. Drawing on extensive research undertaken by the OECD and other international organizations, the workshop examines how investment tax incentives work in theory and in practice as well as their economic advantages and disadvantages. In particular, the workshop focuses on the policy design features that determine whether particular tax incentives are likely to deliver cost-effective and sustainable benefits. Examples of successful and failed tax incentive schemes are illustrated through group case studies and country presentations. While the main focus of the workshop lies on Tax Incentives for Investment, considerable time will be devoted to the broader Tax Expenditure context, including the estimation of the Tax Expenditure revenue cost and Tax Expenditure Reporting.
Target Audience: Policymakers responsible for formulating or evaluating tax incentives and tax administrators responsible for administering them.
7. Taxation of Immovable Property
The aim of the property tax workshop is to provide participants with a thorough knowledge of the different types of property taxes that are levied on immovable (residential and business) property in OECD and non-OECD countries, the impact of these taxes on economic growth, housing prices and the income distribution, the role of property taxes in the financing of sub-central levels of government (i.e. why are recurrent taxes on immovable levied by sub-central levels of government in so many countries), the tax policy criteria which provide guidance on how to design real property taxes (i.e. focusing on efficiency, fairness, revenue potential, accountability, etc.), how to levy recurrent taxes on immovable property in a progressive way, the advantages and disadvantages of transaction taxes on immovable property, an evaluation of the rationale for tax incentives for (residential and business) real property, and the actual experience of OECD countries with taxes on immovable property. The workshop discusses in great detail the valuation of real property, focusing on the different methods that can be used to value real property, a discussion of statistical valuation methods that can be applied, the experiences in OECD and non-OECD countries and some of the best valuation practices, providing also guidance on how to strengthen the valuation methodology in the countries that participate in the workshop. The workshop discusses also the key characteristics and management of fiscal registers and cadastres and the tax administration aspects of property taxation.
Target Audience: Senior tax policy makers and administrators who are involved in the design and implementation of real estate taxes in their countries.
8. Income Tax Workshop
The purpose of this workshop on income tax is to discuss significant tax policy issues in a multilateral setting and to share country experiences on these issues. The content of this workshop is decided on an annual basis in consultation with the participants in order to focus on the most pressing issues facing countries. Topics that have been discussed in previous years include taxation of re-organizations, flat vs. progressive personal income tax rates, EU Directives, tax treatment of revaluation of assets, derivatives and options, tax treatment of employees vs. independent contractors and thin capitalisation rules. Participants are invited to present their country experiences and practical cases relevant to the topics for discussion.
Target Audience: Policy-makers and senior administrators involved in designing and implementing tax reforms.
9. Value Added Tax
Value Added Tax (VAT) is a major revenue raiser for governments around the world and its importance continues to increase. Over 150 countries operate a VAT today, twice as many as in 1992, and this number continues to grow. Many developing countries have adopted VATs during the last two decades to replace lost revenues from trade taxes following trade liberalisation. VAT now raises some 20% of the world’s tax revenues, and many countries are seeking to raise additional revenues from VAT (rather than other taxes) as part of their fiscal consolidation strategies. Finding sensible solutions in the continuing process of improving the efficiency of the VAT system, increasing compliance and adapting to changing economic conditions are among the common challenges faced by countries around the world. Moreover, in a globalised and interrelated economy, there is an urgent need to remove the obstacles created by the currently uncoordinated interaction of VAT systems. In response, the OECD is developing the International VAT/GST Guidelines as an internationally agreed standard for applying VAT to cross-border trade.
Drawing on the outcome of discussions held at the first meeting of the OECD Global Forum on VAT (November 2012), this event will provide a review of the basic structure of the VAT; examine specific problems in the design and implementation of the VAT and discuss policy options to simplify the administration and facilitate compliance.
Target Audience: Senior tax policymakers and tax administrators with responsibility for indirect tax policy/administration and/or tax administration more generally.
10. Micro-Simulation Modelling of Tax Revenues
The purpose of this workshop, aimed at early-career economists, is (i) to provide participants with a working knowledge of micro-simulation principles and techniques in modelling the revenue impacts of tax policy changes, in the areas of personal income tax, corporate income tax, and value-added tax, including the establishment of a database; (ii) to oversee “hands-on” application by participants of micro-simulation techniques; (iii) to provide participants with an overview of measurement issues and policy uses of marginal and average effective tax rates; and (iv) to establish a network of model builders and users which may be useful for participants when practical problems arise.
Target Audience: Participants should be early-career tax policy economists involved in tax modelling in the central government’s Ministry of Finance (or in the Ministry responsible for providing tax modelling services to the Ministry of Finance). Participants should also have a good knowledge of the basic design features of at least one of the following main tax bases -- personal income tax, corporate income tax, and value-added tax -- and some familiarity with spreadsheet analysis (e.g., Excel software.)
11. Implementing Transfer Pricing
The purpose of the event is to discuss the policy and administrative issues that face countries introducing or extending transfer pricing legislation or looking to increase their transfer pricing audit capacity. The event discusses the objectives of implementing TP legislation - to protect tax base against transfer of profits abroad, while avoiding double taxation that would be detrimental to FDI.
The event also discusses how to achieve these objectives from a legislation perspective - what is needed in country legislation, the relationship with tax treaties, etc. Finally we consider how to achieve these objectives from an administrative perspective - where to start from and how to build the administrative capacity over time, especially where resources are scarce.
Target audience: The event is aimed at policy makers in Ministry of Finance or Tax Administration with responsibility for drafting legislation, and high level administrators in charge of organizing the Transfer Pricing function. The event does not cover in detail transfer pricing methods or the practicalities of transfer pricing auditing. It is therefore not suitable for operational transfer pricing auditors (Courses 4, TP1; 5, TP2; 22 AME1; 23 AME2 are more relevant for such officials).
12. Transfer Pricing Guidelines
The course aims to provide an introduction to transfer pricing issues, largely by looking in detail at the OECD transfer pricing guidelines. The topics covered include a description of the arm’s length principle and OECD recognised transfer pricing methodologies, comparability analysis including functional analysis (functions performed, assets used and risks assumed) and introduction to special problem areas, such as intangibles and services including an in depth look at management fees and other intra-group services. The course is designed to be practical in nature, so the topics covered are illustrated by the frequent use of case studies. Time should also be available for a discussion of any difficulties experienced by participants.
Target audience: Senior administrators involved in organising, managing and conducting transfer pricing audits of multinational enterprises.
13. Intermediate Transfer Pricing Guidelines
The purpose of this event is to discuss in detail some of the more difficult practical and theoretical issues arising in transfer pricing. Items discussed include performing a comparability analysis and in depth analysis of profit methods, practical case studies on intangibles and cost contribution arrangements, and dispute resolution/prevention processes such as Mutual Agreement Procedures, Arbitration and Advance Pricing Arrangements. The event also discusses techniques to improve the efficiency of transfer pricing administration, in particular risk assessment techniques.
Target audience: The event assumes prior knowledge of transfer pricing. Participants should therefore either have attended the Introductory Transfer Pricing Event (Transfer Pricing Guidelines TP1) or be experienced transfer pricing auditors or be involved in Competent Authority work.
14. Transfer Pricing- Business Restructurings and Intangibles
The purpose of this event is to discuss in detail some of the more difficult practical and theoretical issues arising in transfer pricing. Items discussed include a review of comparability and transfer pricing methodologies and an in depth discussion and practical case studies on intangibles and business reorganisations. Issues raised by recent transfer pricing court cases will be discussed. Participants are strongly encouraged to provide anonymised case studies in advance of the meeting which can then be used as a basis for discussion at the appropriate point during the event.
Target audience: The event assumes prior knowledge of transfer pricing. Participants should therefore either have attended the Introductory transfer Pricing Event (Transfer Pricing Guidelines) or be experienced transfer pricing auditors or be involved in Competent Authority work.
15. Train the Trainers on Transfer Pricing
The purpose of this programme is to build participants’ skills to conduct transfer pricing training in their own country. The programme focuses both on presentational skills and technical aspects of transfer pricing and is in three phases. The first phase consists of a desk study based on reading materials provided, and a questionnaire to test the participant’s knowledge both of basic transfer pricing and facilitation skills. The second phase of the programme consists of a skills building workshop where participants will be provided with materials to take back and use to train tax staff in their own country, including power point presentations, case studies and keys, course notes for presenters and background reference materials, plus training materials on effective communication and presentation skills. The third phase is an implementation phase where participants develop, submit to the OECD Secretariat and implement an Action Plan for the delivery of workshops for other tax officials in their country. This delivery process will be evaluated by the OECD Secretariat and an accredited certificate issued to the programme participant at completion.
Target Audience: The programme assumes prior knowledge of transfer pricing. Participants should therefore be experienced transfer pricing auditors or be involved in Competent Authority work, and should expect to be involved in delivering country or regional training programmes on transfer pricing.
16. Transfer Pricing Safe Harbours and Simplification
This event discusses the recently revised Section E on safe harbours in Chapter IV of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This new guidance on safe harbours provides opportunities for countries, especially developing countries, to design a transfer pricing compliance environment that makes optimal use of the limited resources available.
Properly designed safe harbours can help to relieve some compliance burdens and provide taxpayers with greater certainty, particularly for cases involving smaller taxpayers or less complex transactions. It encourages, under the right circumstances, the use of bilateral or multilateral safe harbours as they may provide a significant relief from compliance burdens without creating problems of double taxation or double non-taxation. To facilitate negotiations between tax administrations, the new OECD guidance provides sample memoranda of understanding (“MOUs”) for competent authorities to establish bilateral safe harbours for certain classes of transfer pricing cases. The design and development of a bilateral safe harbour on the basis of an MOU will be discussed during the event.
The work on safe harbours was developed by the OECD in the context of a wider project on simplification measures to alleviate the burden for taxpayers and tax administrations including not only safe harbours but also measures concerning documentation requirements, penalties, streamlined procedures and other elements which will be discussed in this event.
Target audience: The event is aimed at policy makers in Ministry of Finance or Tax Administration with responsibility for drafting legislation and guidance, and administrators in charge of organising the Transfer Pricing function. The event does not cover in detail transfer pricing methods or the practicalities of transfer pricing auditing. It is therefore not suitable for operational transfer pricing auditors.
17. Transfer Pricing: Case Studies
This is a very practical programme aimed at exploring how the Transfer Pricing Guidelines can be applied to selected case studies. The case studies to be analysed during the event will normally be real-life cases, provided by the participants to the experts’ team in advance (deleting any references that could compromise the privacy of the taxpayer) or cases selected by the event leader and experts from previous editions of this event.
Target Audience: The programme assumes prior knowledge of transfer pricing. Participants should therefore have attended either the Introductory Transfer Pricing Event (Transfer Pricing Guidelines (TP1) and / or the Intermediate transfer pricing event (TP2)) or be experienced transfer pricing auditors or involved in Competent Authority work.
18. Transfer Pricing Dispute Resolution
The purpose of this event is to discuss mechanisms to prevent and resolve transfer pricing disputes with a view to efficiently avoid or eliminate double taxation. The workshop is designed to address the theoretical and practical issues arising in the resolution and avoidance of transfer pricing disputes. The topics covered include administrative and juridical appeals, corresponding adjustments, Mutual Agreement Procedures (MAPs), arbitration, rulings, safe harbours, and Advance Pricing Arrangements (APAs). The topics are illustrated by case studies and role plays. Participants are strongly encouraged to present their countries’ legislation and practices regarding dispute avoidance and resolution during the event. Time will also be available for a discussion of any difficulties and experiences by participants.
Target audience: Senior administrators involved in Competent Authority or APA work, as well as policy makers with an interest in MAPs, Arbitration and APAs and the use of safe harbours and other dispute prevention measures. The event assumes prior knowledge of transfer pricing. Participants should therefore either have attended the Introductory Transfer Pricing Event (Transfer Pricing Guidelines TP1) or have otherwise become familiar with the main concepts of transfer pricing, the arm’s length principle including comparability, and the OECD transfer pricing methods.
19. Transfer Pricing Aspects of Extractive Industry
The purpose of this event is to discuss in detail some of the more difficult transfer pricing issues typically arising in the extractive industries at both practical and theoretical level. Through the use of an extensive case study, the event aims to provide practical guidance on evaluating transfer pricing risks in the industry, as well as on conducting a comprehensive transfer pricing analysis. In addition to considering the pricing of commodities, the event includes a closer look at corporate financing, services (including high value added services) and the use of intangibles in the extractive industries. . Participants are strongly encouraged to provide anonymised case studies related to the extractive industry in advance of the event which can then be used as a basis for discussion at the appropriate time during the event.
Target audience: the event assumes prior knowledge of transfer pricing and the extractive industries. Participants should be experienced transfer pricing officers and actively engaged in auditing taxpayers involved in the extractive industries.
20. Transfer Pricing and Customs Valuation
The workshop will explore how Customs and Direct taxation authorities can work together to improve taxpayer compliance with regimes and provide taxpayers with a more joined-up and consistent approach. Through the use of case-studies, the workshop will consider the processes countries have in place for the administration of their Customs Valuation and Transfer Pricing regimes, and explore how the two regimes might co-operate to support compliance and ensure consistency of approach.
This event will be held in partnership between the OECD, the World Customs Organisation (WCO), and World Bank/IFC, and is a result of recent initiatives by the OECD and WCO to encourage closer alignment between customs valuation and transfer pricing, and enhanced co-operation between Direct taxation and Customs authorities. The event will be open to officials from Direct taxation and Customs authorities.
Target audience: Officials from country Direct taxation and Customs authorities with prior knowledge of transfer pricing and customs valuation.
21. Transfer Pricing-Advance Pricing Arrangements
The workshop will illustrate the technical and practical aspects of Advance Pricing Arrangements (APAs). It will be based on a case study involving an application for a bilateral APA on a set of complex cross-border transactions set in the electronics manufacturing industry. It will follow the APA process from the acceptance procedure, fact-finding and analysis stages, discussions with the taxpayer, negotiations with the treaty partner, and, finally, through to final agreement. It will illustrate the technical transfer pricing issues involved in complex related-party transactions, as well as the procedural and practical issues involved in considering and agreeing, or otherwise, an APA. The event will be informal and interactive, enabling participating countries to share and discuss their respective approaches to the administration of APAs. The event will include “role-plays” relating to fact-finding, and negotiation with a treaty partner.
Target audience: Officials from country Revenue Authorities with prior knowledge of transfer pricing and some experience in application of Transfer Pricing legislation.
22. Recent Developments in Transfer Pricing
The purpose of this event is to discuss in detail some of the more difficult practical and theoretical issues in transfer pricing such as performing a comparability analysis, application of profit methodologies and how to deal with business reorganisations (case studies). Furthermore, time will be devoted to introducing the transfer pricing issues under the Base Erosion and Profit Shifting project and discussing the Handbook on Risk Assessment and the White Paper on Documentation. Participants are strongly encouraged to provide anonymised case studies in advance of the meeting which can then be used as a basis for discussion at the appropriate point during the event. Participants are also invited to prepare a brief presentation on their countries’ documentation requirements and risk assessment procedures.
Target audience: The event assumes existing knowledge of transfer pricing. Participants should therefore either have attended the Introductory Transfer Pricing Event (Transfer Pricing Guidelines) or be experienced transfer pricing auditors or be involved in Competent Authority work.
23. Transfer Pricing and Intangibles
This workshop will consider how intangibles impact on transfer pricing analyses and audits. It will be practically based and focus on the implications of intangibles in transfer pricing audits. It will consider a number of case studies, including audit cases, which will provide the basis for discussions on: identifying the existence of intangibles, and whether and how an intangible might be significant in transfer pricing analyses; how the existence of intangibles impact on the selection of the most appropriate transfer pricing method; whether and how the parties to a transaction might be entitled to a return in respect of intangibles; whether royalty payments are appropriate, and, if so, how a royalty rate might be determined or evaluated. The event will also consider auditing aspects of “business restructurings” involving intangibles.
Target Audience: Auditors with existing understanding of transfer pricing concepts and some experience in auditing the returns of multinational enterprises.
24. Exchange of Information for Tax Purposes
Exchange of information between tax administrations is the most effective way of combating international tax avoidance and evasion. The aim of this workshop is to share the experiences of OECD and non-OECD economies as regards the exchange of tax information between competent authorities; and to identify ways of improving the efficiency of this process. The workshop will draw upon OECD work in this area. The underlying legal basis for international exchange of information will be examined (Article 26 of the OECD Model Tax Convention, Model TIEA, revised Multilateral Convention on Mutual Administrative Assistance in Tax Matters, other relevant regional instruments on Mutual Assistance). Cases studies will illustrate the key concepts of exchange of information highlighting the balance between the legal obligation to exchange and the limitations that protect taxpayers‟ rights in exchange of information. Besides exchange on request other forms of exchange (spontaneous, automatic, simultaneous tax examinations) will also be presented. Practical advice will be provided on how to organise a Competent Authority Unit, on how to raise the awareness of tax examiners about the potential of exchange of information, and how to make a request for information and to respond to a request.
Target audience: Senior tax and finance officials involved in the legal and practical aspects of exchange of information with tax treaty partners (i.e. competent authority work), heads of Large Taxpayer Units, and senior managers of international tax audit departments.
25. Regional Event on Exchange of Information Focusing on the Global Forum on Transparency and Exchange of Information
The Global Forum on Transparency and Exchange of Information for Tax Purposes, an autonomous organisation of 121 jurisdictions, with its Secretariat at the OECD, monitors compliance with international standards in this area through a process of peer review. The process is in two phases. Phase 1 assesses a jurisdiction’s legal and regulatory framework for transparency and exchange of information; Phase 2 assesses the implementation of that framework and exchange of information in practice. This workshop, led by the Global Forum Secretariat, is aimed at new and potential members in the region. It will explain the peer review process and the standards required for a successful outcome. There will be a strong focus on preparing for Phase 1, including how to identify key elements of the legal and regulatory framework and how to remedy any gaps ahead of a review. Depending on the needs of participants, Phase 2 aspects will also be covered, including the processes involved in effective information exchange.
26. Taking Advantage of the Convention on Mutual Administrative Assistance in Tax Matters and Automatic Exchange of Information (AEOI)
This Multilateral Convention was originally developed by the Council of Europe and the OECD and opened for signature in 1988. In April 2009, the G20 called for action “to make it easier for developing countries to secure the benefits of the new co-operative tax environment, including a multilateral approach for the exchange of information.” In response the OECD and the Council of Europe developed a Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters to bring it in line with the international standard on exchange of information for tax purposes and to open it up to all countries. The amended Convention facilitates international co-operation for a better operation of national tax laws, while respecting the fundamental rights of taxpayers. The amended Convention provides for all possible forms of administrative co-operation between the Parties in the assessment and collection of taxes, in particular with a view to combating tax avoidance and evasion. This co-operation ranges from exchange of information, including automatic exchanges, to the assistance in the recovery of foreign tax claims
The Convention also provides for the possibility of sharing of information obtained for tax purposes by tax authorities with law enforcement and judicial authorities if certain conditions are met. It will allow fighting tax crimes and other financial crimes more effectively by allowing tax and law enforcement agencies to cooperate more closely as recommended in the OECD „„Oslo Dialogue‟‟ to promote a whole of government approach to tackling financial crimes and illicit flows.
This event will discuss the multiple ways to take advantage of this powerful instrument in the areas of exchange of information, assistance in tax collection, exchange of tax intelligence, bilateral/multilateral simultaneous tax examinations and joint audits covering both direct and indirect taxes etc. It will also discuss under what conditions the information received may be shared with law enforcement and judicial authorities to fight money laundering and corruption. There is a special focus on automatic exchange of information as the G-20 has endorsed this modality as the new international standard. We will discuss what types of information can be exchanged automatically and examples of MOU on automatic exchange, describing the various phases of AEOI from the sending country to the receiving country: the capture of the data, their transmission in a standardised manner, the secure systems for transmission, the ways to use the information in the receiving country for data matching against tax returns, risk assessment and tax compliance projects, the importance of providing feedback to the sending country etc. This topic is particularly relevant for countries which have not implemented automatic EoI already and will be considering it in the future.
Target audience: Senior tax and finance officials involved in the legal and practical aspects of exchange of information and assistance in tax collection (i.e. competent authority work), heads of Large Taxpayer Units, senior managers of international tax audit departments). www.oecd.org/ctp/eoi/mutual
27. International Tax Avoidance
This event examines common techniques used by multinational enterprises to reduce their tax burden, with a particular emphasis on tax avoidance in international transactions, and how the different techniques to erode the taxable base and/or to shift profits to where they are subject to a more favourable treatment can be combined. The event focuses on common planning techniques used in relation to financing activities, holding activities and supply chain management. It also addresses responses enacted by governments in their domestic laws and international tax treaties, such as general and specific anti-avoidance measures. A significant part of the workshop will be devoted to case studies and country-specific experience. It will allow experts to share views and experiences, as well as legislative and practical approaches. Participants will be expected to actively contribute and should be prepared to present experiences made in their countries.
Target audience: Senior officials from the Ministry of Finance and the Tax Administration who deal with the taxation of large taxpayers and multinational enterprises and have a good understanding of international tax concepts.
28. BEPS High Level Regional Consultation
At the request of the G20, in July 2013, the OECD released an Action Plan on Base Erosion and Profit Shifting (BEPS) to address global concerns regarding the taxation of cross-broader activities and other challenges to the international tax framework. The work on BEPS is being carried out within the context of the OECD/G20 BEPS Project, to which all non-OECD G20 countries participate as Associates, on an equal footing with OECD countries. The outcomes of the OECD/G20 BEPS Project are expected by 2015, with the first outputs expected for September 2014. The OECD is seeking the views of all countries in carrying out this work.
This event will provide a unique opportunity for high-level tax officials to discuss the content of the BEPS Action Plan. The aim is to discuss country perspectives on both the challenges and potential solutions in relation to BEPS. This high level dialogue is a first key step in the engagement process, which will continue through the Global Forum on Transfer Pricing in March 2014 and the Global Forum on Tax Treaties in September 2014.
Target audience: High level officials of Tax Administrations and policymakers in Ministries of Finance.
29. Auditing Multinational Enterprises
The objectives of the seminar are to provide participants with a basic knowledge of the issues to anticipate when auditing multinational enterprises. The seminar includes discussions of the most significant legal and practical issues to be taken into account. It deals with the creation and legal significance of a multinational enterprise (MNE), the tax principles underlying the operation of an MNE, tax avoidance and anti-avoidance strategies, the operation of tax treaties, and an introduction to transfer pricing and thin capitalisation issues. Furthermore, the “best practice” audit approaches that are adopted to deal with these entities by OECD countries as well as countries participating in the seminar will be examined. Audit examples are included as far as possible to encourage debate and provide a practical basis for the examination of these issues in the work place. The seminar will also deal with the relevant administrative provisions, information requirements and the audit process itself in order to facilitate the work of tax examiners who may have only limited expertise.
Target Audience: Senior and middle tax administrators and tax inspectors responsible for or engaged in the audit of multinational enterprises.
30. Advanced Auditing Multinational Enterprises
The purpose of this event is to discuss strategies for auditing the international aspects of multinational enterprises, with a particular focus on transfer pricing. The event begins with a discussion on the typical features of MNEs and the taxation issues involved in auditing them. This is followed by a case study extending over 4 days that provides an opportunity to discuss the steps MNEs typically take to plan the amount of tax they pay, and where, and the practical issues auditors face. The case study emphasises the importance of information gathering and the utilisation of the information to secure well founded adjustments which are acceptable to the multinational enterprise and other interested tax administrations.
Target audience: senior or experienced auditors dealing with large multinational enterprises, as well as policy makers with an interest in audit practices. They should be familiar with the main concepts of transfer pricing, the arm’s length principle and OECD transfer pricing methods.
31. Advanced Auditing Small and Medium Enterprises
The aim of this seminar is to discuss in more detail the topics analysed in ASME1, as well as strategies to improve taxpayer compliance and discussions on case selection for audit. Attention will also be paid to evaluation and performance measurement. Methods of indirect income measurement will be explored in more depth by discussing practical cases to improve basic understanding of these methods and to further improve participant’s skills to implement these methods in their daily practise. The seminar will also deal with new developed strategies and practices to counteract non-compliant business taxpayers. The main purpose for this event is to provide the participants with a sound understanding of tax audits at advanced level and a comprehensive toolkit for auditing. At the same time, the participants will be further encouraged to develop creative approaches to deal with most domestic audit cases as well as with problems of the shadow economy.
Target Audience: (senior) tax auditors as well as policy makers who are interested in audit practices.
32. Tax Administration: Risk Management
The course aims to provide a broad overview of principles and practices of Risk Management and Taxpayer Service in OECD countries. The course considers ways for Tax Administrations to find a balance between service and enforcement activities.
The topics covered include organization and management of tax administration, general principles and practises of compliance risk management, including risk identification, risk analysis, risk assessment, risk treatment and evaluation, understanding taxpayer behaviour and developing strategies to influence taxpayer behaviour, improving taxpayers‟ compliance, the need for a strategic approach and compliance measurement. The topics in the area of taxpayer service include the mission, vision, goals and values of taxpayer service, taxpayer rights and service delivery standards, market segmentation in service delivery, the use of modern technology, the design of tax awareness programmes, taxpayer assistance programmes and outreach activities, channel strategies and the usage of call centres, government wide programmes to reduce administrative compliance costs for taxpayers, standardization and evaluation of taxpayer service programmes and measurement of performance of tax administrations.
Target audience: Officials from Ministries of Finance and Tax Administrations, involved in designing and implementing tax administration systems, managers of Tax offices and tax inspectors, auditors and other officials dealing with risk management and taxpayer service.
33. Tax Administration of Personal Income Tax
The course aims to provide an overview of the administration of Personal Income Tax based on practices and experiences in OECD countries. The topics covered include characteristics of Personal Income Tax systems, and the characteristics of the different categories of taxpayers paying PIT, improving taxpayer awareness of their rights and obligations and improving compliance by providing information and assistance to taxpayers. Furthermore principles and processes of tax assessment will be discussed including registration and filing, electronic filing and pre populated tax returns, withholding at source systems, and provisional and final assessment, including assessment by estimation.
Attention will also be given to administrative aspects of particular elements of PIT legislation such as the integration of PIT and Corporate Income Tax (CIT) systems, the taxation of capital gains, the taxation of non-cash benefits and the taxation of cash transactions. The seminar will also deal with domestic information exchange between regions and with third parties on individual taxpayers and relevant relationships such as family members and business. Finally attention will be given to staffing and performance issues including public surveys and the handling of complaints about the performance of the Tax Administration.
Target audience: Participants would be tax officials working in the area of Personal Income Tax.
34. Tax Administration: Handling Administrative Debt Collection
Tax collection is one of the most critical aspects of tax administration. The magnitude of tax debts and case inventories is growing in many countries and the policies of fiscal consolidation have increased the need for alternative strategies for collecting revenue. Building on past and current work of the Forum on Tax Administration, this event examines individual country approaches, experiences, best practices and impacts in their conduct of tax debt collection activities.
Target audience: Officials from Ministries of Finance and Tax Administrations who deal with designing and implementing collection systems in Tax Administrations.
35. Tax Administration: Taxation of High Net-Worth Individuals
High net worth individuals (HNWI) pose significant challenges to tax administrations because of the complexity of their affairs, their revenue contribution, the opportunity for aggressive tax planning (ATP) and the impact of their compliance behaviour on the integrity of the tax system. The Forum on Tax Administration has developed comparative work on strategies used by revenue authorities and reached the conclusion that by focussing resources on the HNWI segment, significant improvements in compliance can be achieved. This event examines current practice in order to discuss strategies of revenue authorities for engaging with HNWI in tax compliance.
Target audience: Officials from Ministries of Finance and Tax Administrations who deal with designing and implementing systems for tax administration.
36. Engaging and Involving SMEs and their Intermediaries in Tax Administration Processes
Revenue bodies are increasingly focused on better understanding the behaviour of taxpayers, and in taking advantage of the opportunities offered by engaging and involving taxpayers and their advisors in the design of the tax system and its compliance mechanisms. This is particularly true in the SME segment which is by nature large, heterogeneous and difficult to administer, with traditional measures focused almost exclusively on enforcement.
The Forum on Tax administration has worked on co-design for some time and has published the report “Together for better Outcomes”. This event, building on this work, aims at exploring the opportunities offered by engaging and involving taxpayers and tax intermediaries.
Target audience: Officials from Ministries of Finance and Tax Administrations who deal with designing and implementing systems for tax administration.
37. Capacity Building Programme for Tax Crime Investigators
Financial crime is one of the greatest threats to the economic and social well-being of people living in all countries. Illicit financial activities, such as tax evasion, corruption, computer fraud and money laundering are a global problem demanding a global response. The OECD Capacity Building Programme for Tax Crime Investigators helps countries to detect and investigate financial crimes and recover the proceeds of those crimes, by developing the skills of tax crime investigators through intensive training courses. The Foundation Programme: Conducting Financial Investigations is an intensive three-week course which gives participants a good knowledge of the wide range of issues faced by tax crime investigators in their fight against suspected illicit financial activities.
The course is structured around a number of modules, which will be taught through a combination of lectures, group discussions, practical exercises and course participant presentations.
As the Capacity Building Programme grows, foundation, intermediate and advanced courses will be developed to address key current issues in combating illicit financial flows.
Target audience: The course is suitable for current tax crime investigators and related specialists. There is no requirement for participants to have any prior experience in conducting financial investigations, though a basic familiarity with company financial statements would be of benefit. All instruction on the course will be conducted in English.
38. Tax Treaties Special Issues
The Tax Treaties Special Issues seminar provides participants who have a basic understanding of the application and interpretation of double tax agreements with an opportunity to examine the key articles and difficult issues commonly encountered in tax treaties. This includes treaty provisions relating residence, the meaning of permanent establishment, the taxation of business profits, income and gains from property, personal services income, investment income and intellectual property transactions. It will also cover the special rules of treaty interpretation and other selected topics. The seminar is orientated towards practical issues. As such, the participants are expected to consider a number of case studies in groups and to be prepared to discuss their views and experiences. Participants are introduced to the Commentaries on the Articles of the OECD Model and how to use them to solve treaty application and interpretation questions.
Target Audience: Tax officials who have a basic understand of tax treaties who are becoming involved with the application, interpretation and negotiation of tax treaties.
39. International Tax Avoidance and the Abuse of Tax Treaties
This seminar examines international tax avoidance and the abuse of tax treaties. Countries have become increasingly concerned that their tax bases are being eroded by aggressive tax avoidance and abuse and are looking to protect their tax bases with sustainable solutions. This has prompted the G20 to invite the OECD to develop an Action Plan to find solutions to base erosion and profit shifting (BEPS). The seminar will discuss the common techniques that are used by enterprises to avoid and evade taxes on cross border transactions and examine how tax treaties may be used to facilitate this. The workshop will also cover common responses introduced by governments in their domestic law, tax treaties and administrative systems to counter international tax avoidance and treaty abuse. Particular emphasis will be placed on the treaty related actions set out in the BEPS Action Plan. The seminar will allow experts to share views and experiences, as well as examine legislative and practical approaches. Participants will be expected to actively contribute and should be prepared to present experiences from their countries.
Target audience: Senior officials from the Ministry of Finance and the Tax Administration who are responsible for developing international tax provisions and policies for their countries and those who deal with the taxation of large taxpayers and multinational enterprises. Participants should have a good understanding of international tax concepts.