WHAT WE OFFER

Application of Double Taxation Avoidance Agreements

The course is aimed at a detailed study of the agreement on the avoidance of double taxation. The course will discuss both the OECD and UN tax model conventions, both at the theoretical level and based on practical examples.

• Principles of international taxation, including the distribution of the right of taxation between the source and resident States, the essence of "may be taxed" and "taxed", the exclusion of double taxation - on the basis of methods of inclusion and exemption;

• Rules for determining residency between countries;

• Types of Permanent Establishment, Normal Permanent Establishment, Permanent Establishment of Construction, Permanent Establishment of Agent;

• Taxation of profits from economic activities;

• Taxation of passive income (dividends, interest, royalties);

• Taxation of income received from real estate, capital increase, in the form of salary;

• International shipping;

• Taxation of other income;

• Articles of the Tax Code of Georgia, which are related to the taxation of non-residents;

• Practical examples;

• Persons interested in international tax law;