Introduction

Cross-Border Tax Planning & Treaty Use Training Course offers a comprehensive exploration of international tax principles, focusing on how multinational enterprises (MNEs) and global investors can optimize tax efficiency while maintaining full compliance. Participants will gain a deep understanding of bilateral and multilateral tax treaties, residency rules, and permanent establishment (PE) concepts that determine cross-border tax liabilities. The program provides practical guidance on structuring international operations, mitigating double taxation, and leveraging treaties for tax-efficient business models.

In addition, the course addresses contemporary challenges in treaty interpretation, anti-abuse measures, and the impact of global tax reforms such as BEPS, Pillar One, and Pillar Two. Participants will analyze case studies of real-world treaty applications and cross-border structuring scenarios. By the end of the training, professionals will be equipped to apply treaty benefits responsibly, avoid treaty shopping pitfalls, and design effective tax strategies that align with evolving international standards and regulatory expectations.

Programme Curriculum

Cross-Border Tax Planning & Treaty Use Training Course

Introduction

Course Objectives

By the end of this course, participants will be able to:

Understand the fundamental principles of cross-border tax planning.
Analyze the structure and application of double taxation agreements (DTAs).
Interpret key provisions of OECD and UN model tax treaties.
Determine tax residency and permanent establishment status.
Identify opportunities for lawful tax optimization using treaties.
Evaluate the impact of BEPS and anti-abuse clauses on treaty benefits.
Structure cross-border transactions for maximum tax efficiency.
Manage withholding tax obligations under treaty provisions.
Handle tax audits and disputes involving treaty interpretation.
Assess the role of digital economy taxation and global minimum tax.
Understand transfer pricing interactions with treaty rules.
Apply case law and international precedents in treaty analysis.
Formulate compliant strategies for global tax risk management.

Target Audience

International tax advisors and consultants
CFOs and finance directors
Tax managers in multinational corporations
Legal and compliance officers
Accountants and auditors handling cross-border clients
Investment analysts and financial planners
Government and revenue authority officers
Policy analysts and regulatory professionals

Course Duration: 5 days

Course Modules

Module 1: Fundamentals of Cross-Border Tax Planning

Overview of international tax systems and principles
The importance of tax planning in global business operations
Key drivers of cross-border taxation: source vs. residence
Risk management and compliance considerations
Ethical standards and transparency in tax planning
Case study: Structuring international subsidiaries efficiently

Module 2: Understanding Double Taxation Agreements (DTAs)

The purpose and structure of tax treaties
OECD and UN Model Conventions: similarities and differences
Methods for eliminating double taxation (credit and exemption)
Role of Competent Authorities in treaty application
Treaty shopping and limitation on benefits (LOB) clauses
Case study: Application of DTA between Kenya and the UK

Module 3: Tax Residency and Permanent Establishment (PE)

Determining corporate and individual tax residency
Types of permanent establishments (fixed, dependent agent, etc.)
Attribution of profits to a PE under Article 7 of OECD Model
Recent developments in PE threshold interpretations
Managing PE exposure in digital and service-based businesses
Case study: PE risk management in multinational service firms

Module 4: Withholding Taxes and Cross-Border Payments

Overview of withholding taxes on dividends, interest, and royalties
Treaty-based reductions and exemptions
Managing compliance and reporting obligations
Avoiding double taxation through credit mechanisms
Impact of hybrid mismatches and conduit arrangements
Case study: Treaty relief on cross-border financing structures

Module 5: BEPS, Anti-Abuse Rules, and Treaty Reforms

OECD BEPS Action Plan and its relevance to tax treaties
Principal Purpose Test (PPT) and LOB provisions
Multilateral Instrument (MLI) and treaty modification process
Addressing artificial arrangements and treaty abuse
Implementing substance requirements and beneficial ownership tests
Case study: MLI implementation in Asia and Europe

Module 6: Strategic Cross-Border Structuring

Designing holding, financing, and licensing structures
Location of IP, treasury, and shared service centers
Managing cross-border mergers and acquisitions
Evaluating tax-efficient routes for investment
Integrating treaty planning with transfer pricing strategies
Case study: Cross-border investment structuring in Africa

Module 7: Dispute Resolution and MAP Procedures

Managing treaty-related tax disputes
Mutual Agreement Procedure (MAP) process and best practices
Arbitration mechanisms under tax treaties
Interaction between domestic remedies and MAP outcomes
Avoiding double taxation through proactive dispute management
Case study: Successful MAP resolution in multinational operations

Module 8: Global Tax Trends and Digital Economy

Pillar One and Pillar Two global tax reforms
Digital taxation and nexus rules for online businesses
Tax challenges for e-commerce and platform economies
Cross-border data and IP taxation under modern treaties
Future of tax cooperation and international transparency
Case study: Impact of global minimum tax on treaty planning

Training Methodology

Instructor-led interactive presentations
Real-world treaty application case studies
Group workshops and simulation exercises
Hands-on treaty interpretation and planning sessions
Problem-solving discussions and peer learning
Knowledge assessments and reflection activities

Register as a group from 3 participants for a Discount

Send us an email: info@fineskilltrainingcenter.org or call +254769199797

Certification

Upon successful completion of this training, participants will be issued with a globally- recognized certificate.

Tailor-Made Course

We also offer tailor-made courses based on your needs.

Key Notes

a. The participant must be conversant with English.

b. Upon completion of training the participant will be issued with an Authorized Training Certificate

c. Course duration is flexible and the contents can be modified to fit any number of days.

d. The course fee includes facilitation training materials, 2 coffee breaks, buffet lunch and A Certificate upon successful completion of Training.

e. One-year post-training support Consultation and Coaching provided after the course.

f. Payment should be done at least a week before commence of the training, to Fineskill Training Center account, as indicated in the invoice so as to enable us prepare better for you.

Programme Fee

Duration: 5 Days

Method: Online or Physical

Online Price: $1,000

Physical Price: $1,500

Certification: Accredited Certificate

View Available Dates 📄 Download Course Outline (PDF)

Available Sessions

Location

Month

Year

Oct 19 2026

19 Oct — 23 Oct 2026

💻 Online / Virtual session

Online $1,000