International Taxation Training Course

Duration 5 days 10 modules · 33 contact hours
Level Intermediate Certificate on completion
Who attends Tax Managers, Finance Managers and others
Fee from USD 1,100 KSh 95,000 for Kenyan organisations
Where 52 cities + online See dates by city
Next start 9 Nov 2026 Course code SD-T-029

Before you join: Participants should understand basic corporate income tax concepts, financial statements and common business transactions such as sales, services, loans, royalties and dividends.

Dates & prices

Two start dates a month in every city, and live online on weekdays or weekends. Fees are per participant; classroom fees include tuition, materials, lunch and refreshments, and the certificate.

Suggest a date or city

Showing the next six months. Later dates, other cities and private deliveries for your team are available on request.

Course overview

Cross-border transactions can create taxable presence, withholding obligations, transfer-pricing adjustments and double taxation before a finance team identifies the exposure. A contract signed in one country, services performed in another and intellectual property held elsewhere may trigger competing tax claims. Teams must determine residence, source, treaty access, permanent establishment risk and reporting duties while maintaining evidence that supports the position taken.

This course examines the legal and technical structure of international taxation for professionals responsible for multinational transactions and tax decisions. Participants work through jurisdictional taxing rights, OECD and UN treaty models, permanent establishments, transfer pricing, withholding taxes, foreign tax credits, BEPS measures, Pillar Two, indirect taxes and tax dispute procedures. They learn to classify income, test treaty eligibility, assess controlled transactions, calculate key cross-border tax effects and identify when specialist advice is required.

Teaching combines instructor briefings with guided case analysis, calculations, treaty interpretation, group discussions and tax-risk scenarios based on corporate structures, service arrangements, financing and intellectual-property payments. Participants complete the course with a cross-border tax risk assessment pack containing a transaction review checklist, treaty analysis framework, permanent establishment assessment model, transfer-pricing documentation map and action plan for priority controls.

The course is suited to finance, tax, legal and compliance professionals who already work with financial reporting, corporate tax or international business arrangements. It is particularly relevant where organisations operate subsidiaries, branches, shared-service centres, supply chains or cross-border funding structures.

What you will be able to do

  • Assess residence, source and nexus rules for cross-border income streams
  • Interpret treaty articles using OECD Model Tax Convention principles
  • Determine permanent establishment exposure for fixed places, agents and remote work
  • Apply OECD transfer-pricing methods to controlled cross-border transactions
  • Calculate withholding tax, treaty relief and foreign tax credit effects
  • Evaluate BEPS anti-abuse rules, hybrid mismatches and interest limitations
  • Analyse Pillar Two scope, effective tax rate and charging-rule implications
  • Prepare a cross-border tax risk assessment and control action plan

Benefits of attending

For you

  • Assess treaty, withholding and permanent establishment issues before transactions proceed
  • Contribute more effectively to tax structuring, contract review and finance decisions
  • Interpret OECD guidance and treaty provisions with greater technical confidence
  • Prepare clearer instructions for external tax advisers and local country teams
  • Build evidence-based tax positions for audits, reporting and internal approvals

For your organisation

  • Earlier identification of taxable presence and double-taxation exposure
  • More consistent treatment of cross-border payments and intercompany arrangements
  • Stronger transfer-pricing documentation and treaty-relief processes
  • Better readiness for Pillar Two data collection and reporting decisions
  • Clearer ownership of tax controls, filings and escalation decisions

Course modules

10 modules over 5 days

Participants can determine which jurisdictions may tax common cross-border income streams.

  • Residence, source and citizenship tests determining a taxpayer’s jurisdictional connections
  • Worldwide and territorial systems compared through taxable income allocation
  • Jurisdictional taxing rights mapped for cross-border employment, business and investment income
  • Entity classification differences affecting partnership, branch and corporate tax treatment
  • Double taxation identified as juridical or economic under domestic rules
  • Tax sovereignty limits examined through nexus, source and residence principles

Participants can interpret treaty provisions and assess their effect on taxing rights.

  • OECD and UN Model Tax Conventions: structure, purpose and policy differences
  • Article 4 residence tie-breaker tests applied to dual-resident companies
  • Treaty entitlement assessed through liable-to-tax status and beneficial ownership
  • Articles 6–21 classified by income category and taxing-right allocation
  • Saving clauses, reservations and protocols located before applying treaty provisions
  • Vienna Convention interpretation used with text, context, object and purpose
  • Treaty override risks identified against domestic law hierarchy rules

Participants can identify permanent establishment risks arising from cross-border business activity.

  • Article 5 permanent establishment tests applied to fixed-place business arrangements
  • Fixed-place PE analysis covering disposal, permanence and business-activity requirements
  • Dependent agent PE exposure assessed under authority-to-conclude-contracts tests
  • Preparatory or auxiliary exceptions tested against core revenue-generating functions
  • Construction-site thresholds calculated using project aggregation and treaty-specific time tests
  • Remote-working arrangements reviewed for home-office PE risk indicators
  • PE profit attribution distinguished from transfer-pricing analysis under Article 7

Participants can select and support transfer-pricing approaches for controlled transactions.

  • OECD Transfer Pricing Guidelines applied to controlled cross-border transactions
  • Functional analysis documents functions, assets and risks before pricing selection
  • Comparable uncontrolled price, resale price and cost-plus methods evaluated
  • TNMM and profit split selected using comparability and value-creation evidence
  • Arm’s-length ranges calculated using interquartile statistics and comparable adjustments
  • Intercompany agreements aligned with conduct, risk control and financial capacity
  • Master file, local file and country-by-country reporting requirements distinguished

Participants can determine withholding obligations and available relief for cross-border payments.

  • Withholding tax rates determined for dividends, interest, royalties and service fees
  • Beneficial ownership analysis separates legal title from substantive income entitlement
  • Treaty relief at source compared with refund and reclaim procedures
  • Gross-up clauses model contractual tax cost between payer and recipient
  • Foreign tax credits calculated under limitation, basket and carryforward rules
  • Hybrid payment mismatches identified where deductions and inclusions diverge
  • Repatriation routes compared through withholding, creditability and cash timing

Participants can assess common international anti-avoidance risks and documentation requirements.

  • BEPS Actions linked to treaty abuse, deductions and disclosure obligations
  • PPT and limitation-on-benefits tests applied to treaty-shopping fact patterns
  • Principal purpose documentation distinguishes commercial rationale from tax-driven arrangements
  • Controlled foreign company regimes compared by income type and control threshold
  • Interest limitation rules tested using EBITDA ratios and group escape provisions
  • Hybrid mismatch rules trace deduction/no-inclusion and double-deduction outcomes
  • Mandatory disclosure hallmarks screened for cross-border reportable arrangements

Participants can assess basic Pillar Two exposure, data needs and implementation priorities.

  • GloBE Model Rules position minimum taxation within multinational group reporting
  • Constituent entities and excluded entities identified for scope testing
  • EUR 750 million revenue threshold assessed using consolidated financial statements
  • Effective tax rate computed from covered taxes and GloBE income
  • Income Inclusion Rule, UTPR and QDMTT ordered within charging mechanics
  • Transitional safe harbours assessed using country-by-country report data
  • Data owners and reporting calendar defined for Pillar Two readiness

Participants can identify indirect tax and customs obligations in international supply arrangements.

  • Place-of-supply rules classify cross-border goods, services and digital transactions
  • Import VAT, customs value and tariffs reconciled at border entry
  • Reverse-charge accounting applied to business-to-business services received from non-residents
  • VAT registration thresholds and fiscal representative requirements compared by jurisdiction
  • Customs valuation methods tested using transaction value and related-party adjustments
  • Incoterms 2020 allocate customs declarations, import taxes and documentary responsibilities
  • Digital-services taxes distinguished from VAT and corporate income taxes

Participants can prepare for tax authority challenges and pursue double-taxation relief procedures.

  • Tax audit information requests managed through document preservation and response protocols
  • Corresponding adjustments evaluated after transfer-pricing primary adjustments imposed by another jurisdiction
  • Mutual Agreement Procedure initiated under Article 25 eligibility conditions
  • Advance Pricing Agreements compared as unilateral, bilateral or multilateral certainty tools
  • Arbitration provisions reviewed where MAP fails to resolve double taxation
  • Tax controversy files organise facts, legal positions, evidence and deadlines
  • Penalty exposure reduced through timely disclosure, cooperation and defensible documentation

Participants can establish priority tax controls and an implementation plan for their organisation.

  • Cross-border tax risk register ranks exposures by likelihood, impact and owner
  • Tax control framework assigns approvals, evidence retention and escalation routes
  • Transaction intake checklist captures jurisdictions, counterparties, contracts and payment flows
  • Calendar controls track filings, treaty claims, documentation and reporting deadlines
  • Board reporting separates cash tax, effective tax rate and contingent exposures
  • Post-course action plan prioritises three tax controls and implementation milestones
  • External adviser instructions specify facts, questions, deliverables and decision dates

Exercises and examples are adapted to each cohort's sectors and roles.

What you take back to work

  1. Cross-border transaction tax review checklist
  2. Treaty eligibility and interpretation framework
  3. Permanent establishment risk assessment model
  4. Transfer-pricing documentation requirements map
  5. Pillar Two readiness assessment template
  6. International tax control action plan

Who should attend

  • Tax Managers — need to assess international exposures and coordinate tax positions
  • Finance Managers — need to understand tax consequences of cross-border transactions
  • Financial Controllers — need to support reporting, provisions and tax control evidence
  • Transfer Pricing Specialists — need treaty and permanent establishment context for pricing analysis
  • In-House Legal Counsel — need to identify tax issues in contracts and corporate structures
  • Compliance and Risk Managers — need to maintain cross-border tax governance and reporting controls

Skills and tools covered

Treaty interpretationPermanent establishment analysisTransfer pricing methodsWithholding tax planningPillar Two assessmentTax risk controls

Tools and standards

OECD Model Tax Convention, UN Model Double Taxation Convention, OECD Transfer Pricing Guidelines, GloBE Model Rules

How the course runs

Training methodology

The instructor introduces each area through short technical briefings anchored in treaty articles, OECD guidance and cross-border transaction data. Participants analyse cases involving branches, service arrangements, financing, royalties, transfer pricing and multinational group reporting. Group work applies treaty tests, permanent establishment criteria, withholding calculations and tax-risk prioritisation. Simulations examine competing jurisdictional claims and responses to tax authority requests. Each participant develops an application plan using current or anticipated transactions from their own organisation.

Requirements and prerequisites

Participants should understand basic corporate income tax concepts, financial statements and common business transactions such as sales, services, loans, royalties and dividends. Familiarity with tax returns, tax provisions, transfer pricing or multinational reporting is useful but not essential. The course assumes participants can read contractual and financial information and make reasoned calculations using percentages and financial data. Prior study of international tax law, treaty interpretation or OECD guidance is not required. This is not a course for complete newcomers to accounting or taxation.

A typical training day

08:30 – 10:30First session
10:30 – 10:45Refreshment break
10:45 – 12:30Second session
12:30 – 13:30Lunch and networking
13:30 – 15:00Third session
15:00 – 15:15Refreshment break
15:15 – 16:30Workshop and daily review

Live online deliveries follow the same structure in East Africa Time, with shorter screen blocks and longer breaks.

What the fee includes

  • Instruction by a practitioner facilitator
  • Full course workbook and materials
  • Exercise files, templates and case studies
  • Refreshments and lunch on classroom deliveries
  • Certificate of completion
  • Post-course application plan

Frequently asked questions

Participants should understand basic corporate tax concepts, financial statements and common commercial transactions. Previous experience with tax treaties or international tax law is helpful but not required.

Participants may bring anonymised examples of cross-border transactions, intercompany agreements, payment flows or current tax questions. A calculator or spreadsheet application is useful for the tax calculation elements.

The course is designed for tax, finance, accounting, legal, compliance and risk professionals working with international operations. It is most useful for people who review or support transactions involving more than one jurisdiction.

Corporate tax courses usually focus on domestic taxable income and tax returns, while transfer pricing courses concentrate on controlled-party pricing. This course connects treaties, permanent establishments, withholding, anti-avoidance rules, transfer pricing, Pillar Two and dispute relief.

Participants can use the review frameworks to assess contracts, new market entries, service arrangements, intercompany charges and cross-border payments. The final action plan helps them assign owners, evidence requirements and escalation points for priority risks.

The course runs from 08:30 to 16:30 each day, with about 6.5 contact hours daily. Time is divided among technical instruction, treaty and transaction cases, calculations, group analysis and application planning.

Questions about this course?

Ask about dates, fees, group bookings or running it for your team. Our training team replies by email.

Ask on WhatsApp info@skillsetdevelopment.com

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