The 2004 International Taxation Seminar on OECD Guidelines—Tax Treaties
Date: 2004.7.26 - 2004.7.30
Instructors
Mr. David Partington
David Partington, a New Zealander, works on the OECD's Tax Treaties Unit at the OECD headquarters in Paris. His work is divided between tax treaty policy matters (including the on-going process of updating the OECD Model Tax Convention) and conducting technical seminars on international taxation for tax administrators and policy officials in emerging economies.
As head of OECD’s work with non-OECD economies on treaty matters, David has conducted over 50 seminars throughout the world on a variety of tax treaty issues including the application of treaties, detailed consideration of specific treaty provisions, treaty policy, international tax avoidance and treaty negotiations. David also has a key role in the development and organisation of the OECD annual Global Forum meeting on tax treaties.
Prior to his move to Paris in 1999, David worked for the New Zealand Government as Manager, International Tax Policy. In that role he was heavily involved, for nine years, with the comprehensive reform of New Zealand's international tax regimes and the negotiation of its tax treaties. He was one of the pioneers in the development of the structure of Chinese Taipei’s recent double tax agreements with OECD countries through his work on the negotiation of the New Zealand Taiwan Double Tax Agreement.
Mr. Daniel Luthi
Daniel Luthi, born in 1936, graduated from the Universities of Bern and Geneva. He joined the Swiss Federal Tax Administration in 1968. From 1980 to the end of 1998, he was Head of the Division for International Tax Law and Double Taxation Matters. Since 1999, he is practising as an independent consultant. Furthermore, until February 2001, he chaired the OECD Working Party No. 1 on double taxation. He now is a member of the OECD Advisory Group in international tax matters. He is the ad-personam expert of Switzerland in the United Nations Ad hoc Group on International Cooperation in Tax Matters. He is a visiting professor at the Wirtschafts universitat Wien.
Day |
Topic |
Monday, 26 July |
|
Morning 10:00-12:00 Afternoon 13:30-16:20 |
Overview of tax treaties Permanent establishments: Basic rule and developments Application of permanent establishment definition:
|
Tuesday, 27 July |
|
Morning 9:10-10:00 10:00-12:00 Afternoon 13:30-15:20 |
Application of Permanent Establishment definition to e-commerce Income attributable to permanent establishments Continue presentations and discussions on Income attributable to permanent establishments ? |
Wednesday, 28 July |
|
Morning 9:10-12:00 ? ? ? Afternoon 13:30-16:20 |
Royalties:
Case study and Discussion |
Thursday, 29 July |
|
Morning 9:10-10:00 10:10-12:00 Afternoon 13:30-15:20 15:30-17:20 |
Continue discussions on royalties Application of tax treaties to Trusts and Investment Funds Treaty Shopping & Anti Tax Avoidance |
Friday, 30 July |
|
Morning 09:10-11:00 11:10-12:00 Afternoon 14:00- |
Application of beneficial ownership requirement in tax treaties Discussion & Experience exchange Closing Ceremony |