International Tax Law Summer SchoolThe summer school is designed to bring together young tax professionals and students from Central Asian and other far away countries to Kazakhstan. Participants will have an opportunity to advance their knowledge of International Tax Law by attending the lectures provided by experienced professors, inviting guests tax professionals and experienced research assistants.The program of summer school will consist of a week of intensive work and will include such topics as concepts of international taxation, practical application of double tax treaties, transfer pricing and other anti-avoidance rules, principles of tax planning and regional case studies.
ProgramDay 1. August 13 Time Topic Description09:00-09:30 Opening, Overview of the Course, Introductions09:30-12:00 Introduction to international Residence-based taxation taxation Source-based taxation Double taxation issues Practical Cases based on Domestic Law of Participating Countries12:00-13:00 Introduction to international Role and importance of tax treaties taxation. Focus on Tax Treaties Relationship between tax treaty and domestic tax law Scope of tax treaties (Persons and Taxes Covered) Structure of tax treaty13:00-14:00 Welcome lunch14:00-15:45 Introduction to international Comparison of OECD and UN Model Treaties taxation. Focus on Tax Treaties Types of allocation rules of treaties Double tax relief Practical Case15:45-16:00 Break16:00-18:00 Introduction to international Review of Tax Treaty Network of Participating taxation. Focus on Tax Treaties Countries Analysis of Vienna Convention Interpretation of tax treaties18:00- 20:00 Networking Reception by International Consulting Company
ProgramDay 2. August 14 Time Topic Description09:00- 10:45 Residence concept The concept of residence for Companies The concept of residence for individuals Dual residence issues Treaty tiebreaker rule Practical Case11:00-13:00 Permanent Establishment Concept Introduction Basic rules for the PE concept Definition of PE in OECD and UN Models (article 5) Auxiliary and Preparatory activities Construction sites PE Agency PE Service PE13:00-14:00 Lunch14:00-15:45 Business Profits Analysis of Article 7 of OECD Model Tax Treaty Determination of business profits Arm’s length principle Allocation of expenses16:00-18:00 Employment Income Taxation of dependent personal services General rules Directors’ fees Artists and sportsmen18:00-20:00 Paintball or other Sport / Teambuilding Activity Based on Participants Choice
ProgramDay 3. August 15 Time Topic Description09:00-10:45 Passive Income Taxation of dividends Taxation of royalties Taxation of interest Capital gains11:00-13:00 Beneficial Ownership Concept Definition of beneficial owner Entitlement of benefits13:00-14:00 Lunch14:00-15:45 Non-discrimination Non-discrimination and taxation of business profits Analysis of Protocol of OECD Model Tax Treaty Most-favored nation16:00-18:00 Abuse of tax treaties, treaty shopping Definition of treaty shopping, its significance19:00-21:00 Visit of Kazakhstan National Theatre or other Cultural program
ProgramDay 4. August 16 Time Topic Description09:00-10:45 Introduction to transfer pricing Importance of transfer pricing Associated enterprises Arm’s length principle11:00-13:00 Transfer pricing methodologies Comparable Uncontrolled Price Cost-plus method Resale-price method Profit-split method Transactional Net Margin Method Other methods13:00-14:00 Lunch14:00-15:45 Double tax reliefs methods Credit method Exemption method Limitations on relief Tax sparing credits16:00-18:00 Anti-avoidance rules GAAR Controlled foreign companies Anti-tax havens provisions Limitations on benefits18:00-20:00 Networking Reception by International Consulting Company
ProgramDay 5. August 17Description: Participants are divided into Cases will be focused on the groups following areas: Cases are distributed among teams Taxation of Services Permanent Establishment Passive Income Tax Planning Transfer Pricing
ProgramDay 6. August 18• Trip to Charyn Canyon This is one of the most beautiful places in the country, which is known as Valley of Castles for its unusual rock formations.• It is part of the Charyn National Park.• It is an 80 km canyon in Kazakhstan, which stretches along Charyn River in the northern Tien Shan mountain range
ProgramDay 7. August 19• Trip to Singing Dunes This wonder of nature make an unforgettable impression, which in dry weather sand dune emits a sound like an organ playing. The sound can be heard from several kilometers away.
Enrollment processWe kindly ask for an obliging registration by mailing till June 1st, 2012.We invite you to send us your application including the following: Motivation letter Curriculum Vitae Application form A letter of recommendation from a professor or a lecturerPlease address your application to Karina Muratova; in case you have further questionsplease do not hesitate to contact her.E-mail: TaxSummerSchool@gmail.comPhone: +7 701 2370077
Welcome to Central Asian Tax Research CenterThe Central Asian Tax Research Center (CATRC) is a specialized academic unit engaged in tax-related research and hosted by the School of Law at the Kazakhstan Institute of Management, Economics and Strategic Research (KIMEP).CATRC members perform tax-related research and analytical work, mainly focused on Kazakhstan and Central Asian countries, and to a certain extent on CIS and Eastern/Central European countries. CATRC strives to fill an untapped niche of taxation education in Central Asia and seeks to position itself as a tax research and knowledge hub for Central Asia, as well as a place for professional development and networking. CATRC also serves as a consulting facility for corporate and government entities.
Welcome to Kazakhstan!!!Kazakhstan is the 9th largest country in the world by land area and which is a transcontinental state in Central Asia & Europe.A unique culture with a wide range of traditions and national cuisine.Famous for its beautiful landscape .An abundant supply of accessible mineral and fossil fuel resources.It has chosen a democratic way of development thus a free market.The country is considered to be one of the fastest developing countries in the world and today’s goal of the state is to join the list of the most developed countries.
Сontact Information Republic of Kazakhstan Almaty 050010 2 Abay Avenue KIMEP University, New Building Office 108 Website: www.catrc.kz E-mail: TaxSummerSchool@gmail.com Catrc2011@gmail.com Tel: +7 727 2374757 Ext. 2745, 2747 +7 701 2370077