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                       TaxTreaties2 Early Bird Deadline CGBP What is CPE and MCLE?

30 & 31 MARCH 2011 * 1.5 days - starts at 9:00AM * NEW WORLD HOTEL, MAKATI CITY
Whether you are a Philippine company doing business in another country, or a multinational doing business in the Philippines, there are many tax treaty privileges you can avail of. Explore what these are and learn how to apply them to your advantage!

This one-and-a-half-day seminar is about using tax treaties as a way to maximize tax savings for the benefit of your company and even your expatriates assigned in the Philippines or overseas.

Topics include territories, persons, and taxes covered by the treaties; relief from double taxation; transfer pricing; how to save taxes on your business profits, real and personal properties, investment income including dividends, interest and royalties; employment and personal services income of executives and other top-level officials; and fees of directors, artists, athletes, trainers, teachers and others.
    Who Should Attend:

     • Businessmen & Lawyers
     • CPAs & Tax Practitioners
     • Business Consultants
     • Foreign investors planning to do
       business in the Philippines
     • Representatives from multi-
       national corporations doing
       business in the Philippines
     • Those who want to know how tax
       treaties work in tax savings

Lecturer: Atty. Victorino C. Mamalateo, CPA – he is the author of the newly published book entitled, “Philippine Tax Treaties”. Vic has over 40 years of professional experience in tax practice. He spent 30 years with the BIR as a career service professional, including having been assistant commissioner, and has been an active tax practitioner for 12 years. He has published numerous articles and several other books on tax matters. Having been a bar examiner, he is a sought after lecturer on tax issues and bar review programs in various law schools, colleges and universities.

Panelist: Atty. Marissa O. Cabreros, CPA – BIR Assistant Commissioner for Legal Service covering International Tax Affairs Division. She has jurisdiction on all matters relating to rulings on tax treaties and the processing of tax treaty relief applications. Previously, she was head of the BIR’s International Tax Division. She has a master’s degree in International Taxation from Harvard Law School and a Doctor of Laws from Ateneo de Manila University, where she is also a professor of law. She has been involved in various tax treaty negotiations covering Europe, the Middle East and Asia. She has 21 years of service in the BIR.

Limited Seats Only, Pre-Registration Required

   Avail of Early Bird and

   Seminar Investment is P11,980
   inclusive of Meals, Resource Kit, &
   Certificate of Attendance

   Contact Person: Jessica Ogang
   Manila lines (+632) 556-8968 or 69
   Manila Telefax (+632) 842-7148 or 59
   Cebu lines (+63 32) 512-3106/07
Business World Online Tri-ISys infotxt Powerbooks

Maximizing Tax Savings Using Tax Treaties

Best Practices Approaches, Applications, Updates and Solutions to Tax Issues

New World Hotel, Makati City, Philippines
Wednesday & Thursday, 1.5 days – starts at 9am, March 30 & 31, 2011

Course Outline


     1. Effective Philippine tax treaties with other countries
     2. Methods of adopting tax treaties
     3. Objectives of tax treaties
     4. Definition of terms
     5. General principles in tax treaties
     6. Availment of treaty benefits and relevant BIR forms

     Persons and Taxes Covered
     1. Territories of contracting states
     2. Persons covered by treaties
     3. Taxes covered by treaties

     Permanent Establishments (PE) and Fixed Bases
     1. Permanent establishments
     2. Manners of creating permanent establishments
     3. Types of PE
     4. Essential elements of PE
     5. Tax issues relating to PE (e.g., service income or royalty)
     6. Essential elements for taxation of business profits
          a. Shipping and transport business
          b. Other types of businesses

     Tax on Dividends and Branch Profits
     1. Dividends
     2. Requisites for taxation of dividends
     3. Treaty rates
     4. Branch profit remittance tax
     5. Branch profit remittance tax bases and rates

     Tax on Interest Incomes
     1. Interest income
     2. Requisites for taxation of interest income
     3. Treaty rates

     Tax on Royalties
     1. Tax on royalties
     2. Requisites for taxation of royalties
     3. Most-favored-nation clause

     Tax on Income from Real Property and Capital Gains on Personal Property
     1. Income from real property
     2. Requisites for taxation of income from real property
     3. Gain from sale of movable property

     Income from Dependent Personal Services
     1. Compensation income
     2. Requisites for taxation of compensation income

     Relief from Double Taxation
     1. Methods of avoiding double taxation
          - Deduction Method
          - Exemption Method
          - Tax Credit Method
          - Tax Sparing Method
     2. Additional tax credits allowed by certain countries
     3. Non-discrimination clause

     Transfer Pricing on Transactions between Related Parties
     1. Arm’s length principle
     2. Legal bases for tax adjustments
     3. Transfer pricing methods
     4. Areas and implications of tax adjustments

     Examples of Jurisdictional Conflicts
     1. Source-source conflict
     2. Residence-residence conflict
     3. Residence-source conflict
     4. Nationality-residence-source conflict

* This program will include examples of various scenarios of international transactions common in the Philippine setting.

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- SEMINAR FEE PER PERSON: P11,980 (Fee covers Meals, Resource Kit, Certificate of Attendance)


Less 5% for early registrants (on registrations made on or before March 2, 2011)
Less 5% for early payment (if made on or before March 20, 2011)
Less 5% for group registration (minimum of 3 participants)

REGISTER NOW to avail of Early Bird and Group DISCOUNTS
Share |
Download: Flyer - Black&White (.PDF 427kb)
                         Course Outline (.PDF 186kb)