Case 1 (International Taxation)

Preliminary Learning Materials

Letter to DIPCAT ISP students

Tutorials (Preliminary Recordings)

Overview of Sophia’s Dream Group Tax Case (IO1)
The Right to Tax Corporations
Defining Permanent Establishments
Transfer Pricing

Preliminary Workshop Challenges

International Tax Terminology (word challenges)
Corporate Tax Features (per country template)
SDG Case Study 2020-21 (with Appendix)

Case Study (International Taxation)

SDG Case Study 2020-21 (with Appendix)
Task 1: Analysis of SDG’s Taxing Nexus
Task 2: SDG International Tax Analysis (per country template)
Task 3: Tax Consulting Notices

Additional Materials

Bilateral Agreements on the Elimination of Double Taxation
OECD Art 5 (and commentary)
OECD Art 7 (and commentary)
OECD Art 9 (and commentary)
OECD Transfer Pricing Guidelines