Venturing into overseas business operations can be difficult enough without the added complication of reconciling the associated international tax implications.

Tax laws are becoming more complex internationally as Governments compete with each other for global economic wealth and tax revenue. Double taxation, unresolved tax disputes, uncertainty in the application of international tax rules, heavy compliance burdens, all can act as barriers to the expansion of cross-border trade and investment.

International Tax is an information intensive 2-day seminar that will provide you with the necessary tools and techniques to navigate this potential minefield. Armed with a sound understanding of the key international tax considerations for a kiwi company, you will leave this seminar with the ability to optimise your organisation’s tax position when venturing into overseas markets.

Key learning objectives

• Gain an insight into the current international tax situation and take a look at the proposed changes by Government

• Understand the key profit reduction strategies available including transfer pricing, tax-haven entities and intellectual property arrangements

• Understand the key considerations of transfer pricing and the difference it can make on your profits

• Discuss the issues surrounding Controlled Foreign Corporations, the possible solutions and when they are a good or bad option

• Analyse Foreign Investment Funds and the various methods of calculating their value and returns

• Understand the impact of various tax treaties, how you can use this to your advantage, and take a look at the OECD Model Treaty  

Who should attend?

• CFOs

• Finance Managers

• Financial Controllers

• Accountants

• Treasurers

• Tax, accounting and legal advisors

• Importers

• Exporters

• Bankers

Overview of international tax

This sesison introduces you to the international tax regime under the Income Tax Act 2004 (IT04), basis of taxation. Learn about the concept of residency and source, double tax treaties and credits for foreign tax.

• Introduction, residency and source

• The problem of double tax

• Unilateral relief: Exemption; deduction; credit

• Bilateral relief: treaties

Profit reduction techniques

During this session various methods of international income tax minimisation and tax efficient structuring of commercial transactions are discussed and explained in detail.

• Transfer pricing

• Tax-haven entities

• Re-invoicing

• Financing arrangements

• Intellectual property arrangements

• Captive insurance companies

Transfer pricing

A key component of the international tax scene, transfer pricing refers to the practice of shifting profits from one jurisdiction to another through the manipulation of prices paid for goods, services and intangibles, generally between associated parties. The effect of this price manipulation is that a multi-national group can shift profits to the country that imposes the lowest tax cost.

• The problem

• Comparable uncontrolled price

• Resale price

• Cost plus

• Profit split

• Comparable profit

Controlled Foreign Corporations (CFCs)

This session takes a look at the key aspects of CFCs and what effects they have on your tax situation. The issues surrounding CFCs, the possible solutions and when they are a good or bad option will all be discussed.

• The nature and scope of the problem

• Possible solutions

• Attributed foreign income

• Definition of CFC

• Control interest

• Income interest

• Branch equivalent income

Foreign Investment Funds (FIFs)

This session takes a look at FIFs and how they will affect you with regards to international tax rules. Learn how to analyse FIFs and the various methods of cultivating their value and returns.

• FIF interests

• Comparative value method

• Deemed rate of return method

• Accounting profits method

• Branch equivalent method

Tax treaties

The main purpose of a tax treaty is to solve common double taxation problems and thus reduce barriers, particularly economic barriers between countries. Tax treaties are also designed to provide a climate of certainty of tax treatment for persons affected. This session will take a look at how tax treaties work, the impact they can have and how you can use this to your advantage.

• The OECD Model Treaty

• The “home” state

• The “source” state

• Permanent establishment

• Treaty shopping