Double tax agreements have traditionally been viewed as great shields, allocating taxing rights between jurisdictions, restricting tax rates and forcing jurisdictions to provide credits. But are they well understood? Are they used to their greatest advantage? Where is the line with “treaty shopping”?

This course will be suited to accountants and advisors working with:

• Taxpayers with foreign investments;
• Binational/Multinational groups
• Businesses considering overseas expansion

PART 1 – COMMON ISSUES

In the first part of a two-part webinar, we explore double tax agreements, their usual form and concepts, how to interpret various articles and ensure that they apply to your clients’ situations.

Upon satisfactory completion of this activity you will be able to:

• Determine who is subject to particular double tax agreements
• Apply the residence tie-breaker tests
• Understand the permanent establishment concept
• Determine taxing rights on real estate
• Know the different taxing rates on interest, dividends and royalties
• Assist employers and employees with determining where to comply with employment tax obligations

1.25 CPD hours

To purchase Part 1 only, please click here

PART 2 – OTHER ISSUES AND HOW DTA’S WORK

In part two, we explore the greater complexities that can arise, including limitation of benefits articles, situations where the agreements may not apply, and the changes made by the 2017 Base Erosion and Profit Shifting Multilateral Instrument (“MLI”).

Upon satisfactory completion of Part Two you will be able to:

• Consider taxing rights on superannuation schemes, social security payouts and pensions, along with earnout situations;
• Decipher limitation of benefit articles and how they apply;
• Determine when DTAs may not apply and options available to taxpayers, including the competent authority application process;
• Appreciate how the MLI has changed the landscape of Double Tax Agreements and areas of caution;
• Determine when double tax agreements or changes thereto enter into force and start to benefit your client.

1.25 CPD hours

To purchase Part 2 only, please click here

PRESENTER

Richard Muth, Senior Manager – Tax Advisory, Findex/Crowe

Richard Muth is an experienced taxation practitioner at Findex / Crowe having more than 10 years of experience with clients ranging from large multinational groups, Australasian groups, New Zealand based SMEs along with high net worth individuals.

A core specialty of Richard’s is helping those who are looking to call New Zealand home understand what this means for them from a tax viewpoint. Richard also helps those looking to take up opportunities overseas understand how New Zealand will or will not tax them while they are away.