Cross-border Income Tax Compliance

Lesson

Learning Objectives

Specifics

Part 1

Introduction to Corporate Income Taxation

• Gaining knowledge about the basic principles of national and international corporate income taxation;

• Understanding the difference between corporate income tax and personal income tax;

• Understanding the corporate tax implications of cross-border assignments and the phenomenon of double taxation on corporate income;

• Gaining knowledge about the tenet of Permanent Establishment for tax purposes;

• Being aware of the corporate tax liabilities in connection with the existence of a permanent establishment;

• Being aware that an assignment can implicate the existence of a permanent establishment;

• Being aware that changes in circumstances can have far-reaching consequences in terms of corporate income taxation.

Duration video: 9 minutes

Number of pages handbook: 9

Part 2 

Introduction to Personal Income Taxation

• Understanding that income tax applies not only to corporations but also to income sources that are earned or attained by an individual;

• Gaining knowledge on the tenet of Fiscal Residence personal income tax purposes and knowing how to apply this knowledge;

• Understanding the difference between tax residents and non-residents ;

• Gaining knowledge on the tenet of Employer for personal income tax purposes;

• Gaining knowledge on the tenet of Permanent Establishment for personal income tax purposes.

Duration videos: 6 minutes

Number of pages handbook: 22

Number of quizzes: 13

Part 3

Avoiding Double Taxation on Cross-border Income

• Understanding in which situations cross-border employment can lead to double personal income taxation;

• Gaining knowledge on Double Tax Treaties (DTT) and their purpose in the cross-border employment landscape;

• Understanding what is meant by Allocation Rules;

• Understanding the difference between being subject to taxation and being taxed;

• Understanding when and how to apply a DTT.

Duration videos: 6 minutes

Number of pages handbook: 22

Number of quizzes: 13

Part 4

Connecting the Dots

• Understanding that an assignee's presence abroad can have unforeseen corporate and personal income tax implications;

• Understanding that the financial impact on the company’s profitability from having to pay additional taxes and costs can be substantial;

• Understanding that corporate and personal income tax implications can lead to reputational and financial damage as a result of blacklisting to the equation and the outcome is even more worrying;

• Understanding that as a Global Mobility professional, you sit on top of vital intelligence relevant to address undesired tax liabilities;

• Understanding that stakeholders need to be aware of the risks that come hand in hand with international assignments;

• Being able to recognise where tax implications might arise and what to do when they arise.

Duration video: 4 minutes

Number of pages handbook: 22

Number of quizzes: 6

Part 5

In-depth course

PE & Corporate Income Tax

• Understanding the basic rules of cross-border corporate income taxation;

• Knowing what is meant by a taxable presence;

• Knowing what is meant by PE;

• Understanding the concept of PE, its inclusions and exclusions;

• Understanding what is meant by dependent versus independent agent;

• Understanding what is meant by “double jeopardy”;

• Knowing what is meant by “BEPS”;

• Knowing how BEPS impacts reporting obligations;

• Understanding the relevance of the tenet of PE and BEPS to the GM function.

Duration video: 14 minutes

Number of pages handbook: 10

Number of quizzes: 16

Part 6

In-depth course

PE & Personal Income Tax

• Understanding what is meant by “double jeopardy”;

• Understanding the relevance of the tenet of PE from a personal income tax perspective+

• Understanding the role of the GM function in this regard. 

Duration video lesson: 14 minutes

Number of pages handbook: 4

Number of quizzes: 5

Part 7

In-depth course

The Tenet of the Employer

• Understanding what is meant by "Formal Employer";

• Understanding what is meant by "Economic Employer";

• Understanding what is meant by "Material Employer";

• Understanding the relevance of this distinction for cross-border taxation on personal income;

• Being able to identify the various forms of the Employer in practice.

Duration video: 9 minutes

Number of pages handbook: 22

Number of quizzes: 5