10 March 2011 Stockholm School of Economics Mannheimer Swartling

1. International law firm Mannheimer Swartling
and Stockholm School of Economics in Russia
are pleased to invite you to:
Introduction to International Tax Law
by Professor Kees van Raad (International Tax Center Leiden)
Of Counsel of Loyens & Loeff, a leading Dutch (tax) law firm,
Member of Global Law Faculty New York University (NYU), USA;
Permanent visiting professor of Peking University (PKU) Law School, China;
Chairman of European Association of Tax Law Professors;
Deputy Judge of the Netherlands appellate court (tax chamber).
Tuesday, 1 March 2011, 16:00 – 20:00
Sweden House, Stockholm School of Economics, 4 floor
Malaya Konyushennaya str., 1/3 A
(entrance from Shvedsky pereulok)
Interaction between domestic tax law and tax treaty is often unclear in practice gives rise to
misunderstanding and mistakes. This seminar offers a unique opportunity to gain a thorough
understanding of key concepts of international taxation and tax treaties. The way tax treaties
operate will be demonstrated on the basis of the tax treaty between the Russian Federation and
the Netherlands (1996). This is one of the almost 3,000 (bilateral) tax treaties that are currently
applicable in the world. As virtually all of these treaties (including the one between the Russian
Federation and the Netherlands) are based on the OECD Model, a good understanding of a
single tax treaty implies a good understanding of tax treaty law in general. The seminar will
deal with, inter alia, the following issues:
Interaction between domestic tax law and tax treaty
Interaction between the distributive articles and double taxation relief provisions
Business profits taxation under tax treaties: main rule and exception
Physical PE, construction PE and agency PE
Concept of residence under tax treaties
Tie-breaker rule for dual residence conflict
Dual (multiple) source of income
Complex issues on tax treaty interpretation and application − triangular and
quadrangular cases
Working language of the seminar is English.
The fee is RUB 2,000, including VAT. Please find attached the payment conditions.
Please register for the seminar by e-mail: nag@msa.se before 25 February 2011.
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