Specific knowledge of the complex area of international and customs taxation and transfers, unraveled in a highly educationally effective Executive development program"

Why Study at TECH?

TECH is the world's largest 100% online business school. It is an elite business school, with a model based on the highest academic standards. A world-class center for intensive managerial skills education.   

TECH is a university at the forefront of technology, and puts all its resources at the student's disposal to help them achieve entrepreneurial success”

At TECH Global University

Innovation

The university offers an online learning model that balances the latest educational technology with the most rigorous teaching methods. A unique method with the highest international recognition that will provide students with the keys to develop in a rapidly-evolving world, where innovation must be every entrepreneur’s focus.

"Microsoft Europe Success Story", for integrating the innovative, interactive multi-video system. 

The Highest Standards

Admissions criteria at TECH are not economic. Students don't need to make a large investment to study at this university. However, in order to obtain a qualification from TECH, the student's intelligence and ability will be tested to their limits. The institution's academic standards are exceptionally high...  

95% of TECH students successfully complete their studies.

Networking

Professionals from countries all over the world attend TECH, allowing students to establish a large network of contacts that may prove useful to them in the future.  

100,000+ executives prepared each year, 200+ different nationalities.

Empowerment

Students will grow hand in hand with the best companies and highly regarded and influential professionals. TECH has developed strategic partnerships and a valuable network of contacts with major economic players in 7 continents.  

500+ collaborative agreements with leading companies.

Talent

This program is a unique initiative to allow students to showcase their talent in the business world. An opportunity that will allow them to voice their concerns and share their business vision. 

After completing this program, TECH helps students show the world their talent. 

Multicultural Context

While studying at TECH, students will enjoy a unique experience. Study in a multicultural context. In a program with a global vision, through which students can learn about the operating methods in different parts of the world, and gather the latest information that best adapts to their business idea. 

TECH students represent more than 200 different nationalities.  

Learn with the best

In the classroom, TECH’s teaching staff discuss how they have achieved success in their companies, working in a real, lively, and dynamic context. Teachers who are fully committed to offering a quality specialization that will allow students to advance in their career and stand out in the business world. 

Teachers representing 20 different nationalities. 

TECH strives for excellence and, to this end, boasts a series of characteristics that make this university unique:   

Analysis

TECH explores the student’s critical side, their ability to question things, their problem-solving skills, as well as their interpersonal skills.  

Academic Excellence

TECH offers students the best online learning methodology. The university combines the Relearning methodology (the most internationally recognized postgraduate learning methodology) with Harvard Business School case studies. A complex balance of traditional and state-of-the-art methods, within the most demanding academic framework.   

TECH is the world’s largest online university. It currently boasts a portfolio of more than 10,000 university postgraduate programs. And in today's new economy, volume + technology = a ground-breaking price. This way, TECH ensures that studying is not as expensive for students as it would be at another university.   

At TECH, you will have access to the most rigorous and up-to-date case analyses in academia” 

A tailor-made program that is taught in a 100% online format so you can choose the time and place that best suits your availability, schedule and interests.  

Developed over 6 months and intended to be a unique and stimulating experience that will lay the foundations for your professional success.

Specific knowledge of the complex area of International and Customs Taxation and Transfer Fees, unraveled in a highly effective educational program"

Syllabus

This complete specialization offered by TECH Global University is an intense program that prepares you to face challenges and business decisions globally. 

The content is designed to promote the development of skills that allow for more rigorous decision making in uncertain environments. 

Over the course of 900 hours, the student analyzes a plethora of practical cases through individual and team work. It is, therefore, a genuine immersion in real scenarios that will help you to deal with complex situations in your daily practice.  

A plan designed for you, focused on your professional improvement and that prepares you to achieve professional excellence. A program that understands both yours and your company's needs through innovative content based on the latest trends, and supported by the best educational methodology and an exceptional faculty, which will provide you with the skills to solve critical situations, creatively and efficiently. 

This program is developed over 6 months and has 6 modules: 

Módulo 1. Basic Principles of International Taxation and Non-Resident Income Tax
Módulo 2. European Taxation
Módulo 3. Double Taxation Treaties 
Módulo 4. Transfer Pricing
Módulo 5. Customs
Módulo 6. Indirect Taxation on Foreign Trade

Where, When and How is it Taught?

TECH offers students the possibility of taking this Executive development program in International Taxation, Transfer Pricing and Customs completely online. Throughout the 6 months of specialization, they will be able to access all the contents on the program at any time, allowing them to self-manage their study time.

Module 1. Basic Principles of International Taxation and Non-Resident Income Tax

1.1. Basic Principles of International Taxation 

1.1.1. Introduction to International Taxation 
1.1.2. Residence Principle vs. Source Principle 
1.1.3. International Double Taxation, Concepts, Types and Solutions 

1.2. Description of Methods to Avoid Double Taxation 

1.2.1. Introduction  
1.2.2. Exemption Method 
1.2.3. Imputation Method 
1.2.4. Methods to Avoid Double Taxation under Spanish Law  

1.3. Nature, Purpose and Scope of Non-Resident Income Tax Application.  Personal Elements of Non-Resident Income Tax  

1.3.1. Introduction.  Nature, Purpose and Scope of Non-Resident Income Tax Application. 
1.3.2. Non-Resident Income Taxpayers and Persons Liable for Non-Resident Income Tax  
1.3.3. Residence  
1.3.4. Representatives  

1.4. General Non-Resident Income Tax Rules   

1.4.1. Tax Liability.  Taxable Transaction 
1.4.2. Income Obtained in Spanish Territory - article 13 LIRNR  
1.4.3. Exempt Income - Article 14 LIRNR   

1.5. Non-resident Taxation Without Permanent Establishment 

1.5.1. Taxable Income. Composition and Specific Rules
1.5.2. Tax Rate.  Applicable Tax Rates  
1.5.3. DEVE 
1.5.4. Calculation of Tax Debt 
1.5.5. Permanent Establishment Diversity. Tax Period and Accrual 

1.6. Real Estate Taxation

1.6.1. Concept of Real Estate in Spanish Law and in Double Taxation Treaties  
1.6.2. Taxation of Capital Gains Obtained Though Real Estate Sales. Movable Assets vs. Real Estate Assets 
1.6.3. Taxation of Real Estate Income 
1.6.4. Special Tax on Real Estate Assets of Non-resident Entities  

1.7. Entities under the Income Attribution Regime 

1.7.1. Introduction to Entities under the Income Attribution Regime 
1.7.2. Entities under the Income Attribution Regime Incorporated in Spain, Taxation of Non-resident Members 
1.7.3. Entities under the Income Attribution Regime Incorporated Abroad

1.8. Non-Resident in European Union vs Rest of the World Comparison  

1.8.1. Dividends, Interest, Royalties, Capital Gains 
1.8.2. Taxable Income. Rules Applicable to EU Residents 
1.8.3. Applicable Tax Rate  

Module 2. European Taxation

2.1. General Aspects of European Tax Law

2.1.1. Introduction
2.1.2. Taxation in the European Union Treaties: Legal Basis for Tax Harmonization
2.1.3. General Concepts of European Law and Taxation
2.1.4. European Tax Policy

2.2. The Parent-Subsidiary Directive

2.2.1. Introduction
2.2.2. Main Features
2.2.3. Content
2.2.4. Application Requirements
2.2.5. The Parent-Subsidiary Directive and Tax Avoidance: Abuse of European Law and Anti-Abuse Clauses
2.2.6. Transposition in Spain 

2.3. Interest and Royalty Directive

2.3.1. Introduction
2.3.2. Main Features
2.3.3. Application Requirements
2.3.4. The Interest and Royalties Directive and Tax Avoidance: Abuse of European Law and Anti-Abuse Clauses
2.3.5. Transposition in Spain 

2.4. The Directive on Corporate Restructuring

2.4.1. Introduction
2.4.2. Main Features
2.4.3. Restructuring Cases Covered by the Directive
2.4.4. Fiscal Regimen
2.4.5. Anti-Abuse Provisions

2.5. Anti-Tax Avoidance Directives I (ATAD I)

2.5.1. Introduction
2.5.2. Main Features
2.5.3. Areas
2.5.4. Anti-Tax Avoidance Clauses in the Directive
2.5.5. Transposition in Spain 

2.6. Anti-Tax Avoidance Directives II (ATAD II)

2.6.1. Introduction
2.6.2. Main Features
2.6.3. Areas
2.6.4. Anti-Tax Avoidance Clauses in the Directive
2.6.5. Transposition in Spain 

2.7. State Aid and Taxation

2.7.1. Introduction
2.7.2. General Aspects
2.7.3. Concurrence Requirements
2.7.4. Nature of State Aid

2.8. Administrative Cooperation

2.8.1. Introduction
2.8.2. General Aspects
2.8.3. The Directive on Administrative Cooperation

2.9. The Intermediaries Directive (DAC 6)

2.9.1. Introduction
2.9.2. General Aspects
2.9.3. Areas
2.9.4. Contents and Definitions
2.9.5. Transitional Period
2.9.6. Transposition of the Directive in Spain 

2.10. The Role of the Court of Justice of the European Union

2.10.1. Introduction
2.10.2. Preliminary Ruling
2.10.3. Main CJEU Rulings

Module 3. Double Taxation Treaties 

3.1. Different Models of Double Taxation Avoidance Treaties and Exchange of Information Agreements

3.1.1. Introduction to Double Taxation Treaties. Evolution of Double Taxation Treaties Over Time
3.1.2. Different Double Taxation Treaties Models. OECD vs UN vs US
3.1.3. Information Exchange Agreements

3.2. Basic Concepts of Commentaries to the OECD Model

3.2.1. Introduction to Commentaries to the OECD Model
3.2.2. The Role of Commentaries to the OECD Model
3.2.3. Reservations on Commentaries to the OECD Model

3.3. Articles 1 to 4 - OECD Model Tax Convention

3.3.1. Persons and Taxes Covered
3.3.2. General Definitions
3.3.3. Residence

3.4. Article 5: Permanent Establishments - OECD Model Convention

3.4.1. Concept of PE
3.4.2. Fixed Place of Business
3.4.3. Dependent vs. Independent Agent
3.4.4. BEPS Impact on Article 5

3.5. Article 7: Business Benefits - OECD Model Tax Convention

3.5.1. Corporate Profit Concept
3.5.2. Obtaining Business Profits by a Permanent Establishment
3.5.3. Taxation of Permanent Establishment Income
3.5.4. Deductibility of Expenses for a Permanent Establishment

3.6. Article 10 and 11 - Dividends and Interest - OECD Model Tax Convention

3.6.1. Concept of Dividends
3.6.2. Taxation of Dividends
3.6.3. Concept of Interest
3.6.4. Taxation of Interest

3.7. Article 12: Royalties - OECD Model Tax Convention

3.7.1. Concept of Royalties
3.7.2. Treatment of Technical Assistance and Other Related Services
3.7.3. Taxation of Royalties

3.8. Article 13: Capital Gains - OECD Model Tax Convention

3.8.1. Concept of Capital Gains
3.8.2. Taxation of Capital Gains
3.8.3. Corporate Reorganization Clauses

3.9. Exemption and Taxation Methods in the OECD Model Convention

3.9.1. Exemption Method
3.9.2. Imputation Method
3.9.3. Tax Sparing Clause

3.10. Benefit Limitation Clauses and Other Clauses in the OECD Model Convention

3.10.1. Introduction to Benefit Limitation Clauses
3.10.2. LOB Clause - MLI Proposal
3.10.3. Principle Purpose Test 
3.10.4. Most Favored Nation Clause

Module 4. Transfer Pricing

4.1. Introduction to the Arm's Length Principle

4.1.1. Introduction to the OECD Guidelines
4.1.2. Introduction to the European Transfer Pricing Forum
4.1.3. BEPs Plan and Its Actions Related to Transfer Pricing

4.2. Spanish Transfer Pricing Legislation 

4.2.1. Engagement Principles
4.2.2. Introduction to Transfer Pricing Methods
4.2.3. Introduction to Intragroup Services

4.3. How to Document Related-party Transactions (BEPs - Action 13)

4.3.1. Functional Analysis
4.3.2. Determinant Factors for Comparability
4.3.3. Search for Comparables

4.4. Introduction to the Valuation of Related-party Transactions

4.4.1. How to Identify and Group Transactions
4.4.2. Financial Segmentations When There are Multiple Functions in the Entity
4.4.3. Model 232

4.5. Valuation Methods

4.5.1. CUP Method– Theoretical– Practical
4.5.2. Incremental Cost and Resale Price– Theoretical– Practical
4.5.3. Profit Split– Theoretical– Practical
4.5.4. TNMM Method– Theoretical– Practical

4.6. Special Considerations in Intragroup Services (BEPs Action 10)

4.6.1. Identification of the Services that Generate Benefits. Case Study: Interviews
4.6.2. Determination of the Intragroup Charge
4.6.3. How to Distribute the Charge Among the Subsidiaries

4.7. Introduction to Intragroup Financial Operations

4.7.1. Determination of Interest Rates. Level of Debt
4.7.2. Introduction to Cash Pooling: Mechanisms
4.7.3. BEPs– Action 4

4.8. Special Considerations

4.8.1. Definition of an Intangible Asset
4.8.2. Transfer of Intangible Assets: Alternatives
4.8.3. Legal Ownership vs. Economic Ownership

4.9. Introduction to Advance Pricing Arrangement (APA). Unilateral, Bilateral and Multilateral Procedures

4.9.1. Which are the Most Frequent Operations for Requesting an APA. How and When
4.9.2. Advantages and Disadvantages
4.9.3. Practical Case

4.10. PT Inspections:  Hot Topics

4.10.1. How to Prepare for a Potential Inspection
4.10.2. Relationship and Interaction with the Group
4.10.3. Amicable Procedures– Arbitration– Multilateral Instruments 

Module 5. Customs

5.1. General Aspects of the Movement of Goods

5.1.1. Introduction
5.1.2. General Provisions and Concepts
5.1.3. Applicable Regulations and Scope of Application

5.2. Elements on Which the Application of Import or Export Duties is Based

5.2.1. Common Customs Tariff and Tariff Classification of Goods
5.2.2. Determination of the Origin of Goods
5.2.3. Preferential and Non-preferential Origin

5.3. Customs Value of Goods

5.3.1. Customs Valuation Methods
5.3.2. Transaction Value
5.3.3. Elements to be Included and Excluded When Determining the Customs Value by Means of Transaction Value

5.4. Customs Debt

5.4.1. Origin of Customs Debt
5.4.2. Guarantee for a Customs Debt
5.4.3. Collection, Payment, Drawback and Remission of Import or Export Duties

5.5. Inclusion of Goods in a Customs Statute

5.5.1. Customs Status of Goods
5.5.2. Placing Goods Under a Customs Procedure
5.5.3. Checking and Release of Goods
5.5.4. Disposition of Goods

5.6. Release for Free Circulation and Import Duty Exemption

5.6.1. Inbound Goods
5.6.2. Release for Free Circulation
5.6.3. Import Duty Exemption

5.7. Special Regimes (I)

5.7.1. General Provisions
5.7.2. Transit
5.7.3. Deposit
5.7.4. Free Zones

5.8. Special Regimes (II)

5.8.1. Temporary Importation
5.8.2. Final Destination
5.8.3. Improvement

5.9. Exit of Goods from the Customs Territory of the Union

5.9.1. Formalities at Departure of Goods
5.9.2. Export and Outbound Declaration
5.9.3. Single Administrative Document

5.10. Relevant Issues in Customs Practice

5.10.1. Incoterms
5.10.2. Trade Defence Measures
5.10.3. Customs Representation
5.10.4. Authorized Economic Operator

Module 6. Indirect Taxation on Foreign Trade

6.1. General Aspects 

6.1.1. Foreign Trade Taxes 
6.1.2. The Purpose of Different Levies  
6.1.3. Tax Adjustments on the Border 
6.1.4. Single Market 
6.1.5. Value Added Tax 

6.2. Introduction  

6.2.1. General Aspects 
6.2.2. Single Market and Harmonization in the European Union 
6.2.3. Territory of IGIC (Canary General Indirect Tax) and IPSI (Tax on Production, Services and Imports) Tax Application 

6.3. Intra-Community Deliveries and Transactions 

6.3.1. Place of Performance 
6.3.2. Passive Entity 
6.3.3. Applicable Exemptions 

6.4. Intra-Community Acquisition and Transactions 

6.4.1. Place of Performance, Accrual, Taxable Income and Passive Entity 
6.4.2. Applicable Exemptions 
6.4.3. Intra-Community Transportation of Goods 

6.5. Individual Regimes 

6.5.1. Non-subjection to Taxation of Intra-Community Acquisition of Goods by Certain Persons 
6.5.2. New Means of Transportation 
6.5.3. Remote Sales 

6.6. Exportation and Transactions 

6.6.1. Export Exemption 
6.6.2. Exemptions for Transactions Treated as Exports 
6.6.3. Exemptions in Exempt Areas and Suspension Regimes 

6.7. Imports and Transactions (I) 

6.7.1. Taxable Transaction 
6.7.2. Accrual 
6.7.3. Taxable Income 

6.8. Imports and Transactions (II) 

6.8.1. Passive Entity 
6.8.2. Income Tax Authorities 
6.8.3. Exemptions 
6.8.4. Excise Taxes 

6.9. Elements Common to Excise Taxes (I) 

6.9.1. General Aspects and Harmonization in the European Union 
6.9.2. Excise Taxes in Spain and Their Scope of Application  
6.9.3. Taxable Transaction and Non-Liability Cases 

6.10. Elements Common to Excise Taxes (II) 

6.10.1. Taxable Income, Passive Subject, Exemptions and Refunds 
6.10.2. Suspension Regime and Tax Impact 
6.10.3. Formal Obligations

The teaching materials of this program, elaborated by these specialists, have contents that are completely applicable to your professional experiences”