Master’s in International Tax Advisory
Dirección del programa:
María Lorente Iranzo.
Centro:
Barcelona
Fecha:
October
IDIOMA:
Spanish
ESTANCIA ACADÉMICA:
Universidad de Miami
COLABORAN
GRANDES CENTROS
¿QUIERES SABER MÁS?
SOLICITA MÁS INFORMACIÓN
K
Comunidad de alumni global especializada en Derecho
En rankings de formación en Derecho y en los de profesorado
%
De empleabilidad en las mejores firmas y despachos de abogados
Introducción y objetivos
The market demands advisors trained in international taxation. It could not be otherwise in a context where companies and even individuals constantly operate beyond national borders. To help their clients achieve their goals, they must be fully familiar with the regulations, case law, and administrative doctrine applicable to international taxation, in order to substantiate their strategic and legal position before clients or in the face of potential tax inspections.
The acquisition of this knowledge and skills at the highest level can only be achieved alongside the most renowned specialists from the most prestigious firms. It will be them who, through a method based on Business Cases, analyzing and solving real cases, will ensure that students acquire those skills demanded by the market. The integration phase with these firms, included in this program, also provides the most natural way to end up working in them.
In the context of the 4.0 revolution, it is also essential to have knowledge of technologies with a tremendous impact in the tax field, such as Blockchain and Smart Contracts, as well as working in the most efficient way with digital tools and using agile methodologies. For this, students in this program will receive a course in Digital Business Skills, taught by ISDI, the leading digital training school, which will certify the training received in these areas with a degree.
Patrocinadores
Estructura, localización y calendario
On Mondays, students are provided with videos and study material, which they must work on throughout the week.
On Friday afternoons (Spain time), classes take place in either in-person or streaming format. The preparation of the material throughout the week allows these classes to have a much more practical and Socratic format.
Students who wish to do so can also opt for an internship, lasting between 3 and 6 months.
In all cases, students must complete a master’s thesis (TFM).
Salidas Profesionales
- Consulting and auditing firms or Big Four (mainly in areas related to Tax Law).
- Large national and international companies, listed or SMEs (mainly in departments specializing in financial and tax advisory).
- Banks, investment banks, savings banks, and other financial market operators.
PROGRAMA ACADÉMICO
OPTIONAL LEVELING MODULES
Accounting
- Accounting and registration obligations
- Books-register of income and expenses
- Books-register of investment assets
- Provision of funds and disbursements
Structure of the general accounting plan
- Conceptual framework
- Registration and valuation standards
- Annual accounts
- Chart of accounts
- Definitions and accounting relationships
Relations with taxation
- Corporate tax
- VAT
Socio-economic crimes
- Tax crime and money laundering
- Subjective and objective elements
- Insolvency relationship with money laundering
Criminal compliance
- Tax risk and liability exemption plan
Introduction to direct and indirect taxation of residents
Direct taxation
- Personal Income Tax (IRPF)
- Corporate Tax (IS)
- Inheritance and Gift Tax (ISGF)
- Inheritance Tax (ISD)
- Environmental taxes (on the value of electrical production, value of gas, oil, and condensates extraction, etc.)
Indirect taxation
- VAT
- Transfer Tax and Stamp Duty (ITP and AID)
- Excise taxes (IIEE)
- Financial transaction tax
- Tax on certain digital services
- Environmental taxes (fluorinated gases, waste, etc.)
CORE I: INTERNATIONAL DIRECT TAXATION
PILLARS OF INTERNATIONAL TAXATION
- Sources of international taxation
- EU legal framework (with special reference to Directives)
- Types of international double taxation treaty models
- OECD (BEPS, Pillars I and II)
- Basic principles of international taxation: territoriality criteria (residence and source) and nationality
- General and special anti-abuse clauses, with special reference to “non-cooperative jurisdictions” (tax havens)
- Business case
TAXATION WITHOUT DTT (Non-resident income tax – IRNR)
- Objective and subjective elements of the taxable event
- Analysis of taxation through Permanent Establishment (PE)
- Analysis of taxation without PE
- Business cases
TAXATION THROUGH DTT
- Concept and structure
- Residence
- PE
- Criteria for the distribution of tax sovereignty (real estate, business, maritime navigation, dividends, interest, royalties, capital gains, dependent work, artists and athletes, other income)
- Methods for eliminating double taxation
- Mutual agreement procedure and arbitration
- Business case
TAX IMPACT OF SPANISH INVESTMENT ABROAD
- International tax transparency
- Image rights
- Exit tax
- Hybrid instruments
- Foreign holding company regime
- Expatriates and impatriates regime: “tax nomads”
- Business case
TAXATION OF NON-RESIDENTS AND ITS IMPACT ON OTHER TAXES
- Wealth and large fortunes taxes
- Inheritance and donations tax
- Other taxes (regional and local)
TRANSFER PRICING REGIME
- Arm’s length principle
- Comparability analysis
- Valuation methods
- Formal obligations and sanctioning regime
- Business case with interaction between international direct and indirect taxation
CORE II: INTERNATIONAL INDIRECT TAXATION
VAT WITHIN THE EU AND OUTSIDE THE EU
- VAT in international exchange and trade of goods
- VAT in international exchange of services – Business cases/real cases
- National and international regulations: introduction to Law and EU case law
- Brexit: impact on VAT treatment – Business cases/real cases
- Localization / Territoriality rules
- VAT Permanent Establishment vs Direct taxation Permanent Establishment – Business cases/real cases
- Taxable person – Subsidiary vs. Branch vs other PE
- Obligations – VAT formalities for non-residents
- VAT deduction for non-residents
- Planning – VAT optimizations at the international level – Business cases/real cases
- E-commerce and distance sales
- Approach to inspection activities for non-residents
CUSTOMS AND FOREIGN TRADE
- Customs territory of the Union – Legal framework and territorial scope
- Customs and elements involved in customs clearance
- Fundamental pillars for the application of import duties and other measures in goods trade:
- Common customs tariff and tariff classification of goods
- Customs origin of goods
- Customs value of goods
- Customs debt: Determination of import duty amount. Tariffs and commercial defense measures
- Current case: China – United States trade war
- VAT – Taxable event of import: Accrual, exemptions, suspension, and deferral
- Incoterms® 2020: Practical application and interaction with international taxation
- Inclusion of goods in a customs regime: Special regimes:
- Transit: External and Internal
- Deposit: Customs warehouse and free zones
- Special destination: Temporary importation and final destination
- Processing: Active and Passive
- Fiscal regimes: Non-customs warehouse
- Business case: Real case – Import and customs optimization
SPECIAL TAXES
- Special taxes: Nature and structural elements
- Internal and community territorial scope
- Manufacturing special taxes:
- Taxes on alcohol and alcoholic beverages
- Tax on hydrocarbons
- Tobacco tax
- Special tax on certain means of transport
- Special tax on electricity
- Special tax on coal
- Formalities and management of different taxes
- Introduction to environmental taxation:
- Legal framework
- IVPEE, fluorinated gases, waste, and non-reusable plastic packaging
- Tax on financial transactions
- Tax on certain digital services
ITINERARY A: LEGAL ASSISTANCE IN TAX PROCEDURES
- Management procedure
- Inspection procedure
- Collection procedure
- Administrative and criminal sanctioning procedure
- Review procedure. Claims/Appeals before administrative and judicial bodies/Prejudicial Question
- Cooperative relations. Tax compliance
- Business cases
ITINERARY B: CORPORATE RESTRUCTURING OPERATIONS
- Transformation of companies, merger of companies, spin-off of companies, relocation of the corporate domicile
- Tax impact between parent and subsidiary companies and within group companies
- Contribution of business units
- Special reference to cross-border mergers and spin-offs
- Business cases
PROFESORADO
- Alberto Olmo – RSM – Manager
- Alexandra Benavides – PWC – Partner
- Beatriz Larrosa – EY – Manager
- Beltrán Sánchez – Andersen – Partner
- Cristóbal Martell – Martell Abogados – Partner
- Francisco Javier Rodríguez – Bové Montero – Tax Director
- Ignacio Torres – Uría Menéndez – Lawyer
- Jaime López – RSM – Partner
- Jordi Brotons – Conversa TAX&LEGAL – Partner
- Jordi Hernández – KPMG – Partner
- Josep Cabot – Crowe – Associate Director
- Juan Zornoza – Deloitte – Of Counsel
- Maite Vallet – Maite Vallet – Founder
- Maria Lorente – EY – Partner
- Maria Saló – Martell Abogados – Partner
- Maximino Linares – EY – Partner
- Moisés Oller – Cuatrecasas – Partner
- Nuria Nicolau – Cuatrecasas – Partner
- Pablo Chico – Urjc – Professor
TÍTULO ACREDITATIVO
Once the relevant Program has concluded and ISDE has verified that the STUDENT has completed their work satisfactorily, the STUDENT will receive the corresponding Degree certificate for each PROGRAM.
In compliance with current legality and, specifically, as set forth in article 4.4 of decree 84/2004, it is noted that ISDE’s programs are professionally oriented and therefore, unless explicitly stated otherwise, they are courses that do not lead to the acquisition of a title with official value, but to that of a proprietary title from ISDE.
CHATEA CON
ISDE IA