INTERNATIONAL TAXATION (2 Credits)

Learning Outcomes:

On successful completion of this course, students will be able to: explain International taxation and double taxation issues related to international taxation; analyze International tax avoidance and non-discrimination principles and process of double tax avoidance agreement: tax planning, treaty shopping, beneficial owner, controlled foreign corporation, thin capit; analyze International tax issues on PE and business profits; explain International Taxation of Shipping and Air Transportation of international taxation; analyze Passive income and capital gain of international taxation; analyze Personal and other income of international tax issues.

Topics:

1. Introduction of International Taxation in Indonesia;
2. Introduction – International taxation –  Model and Tax Treaty structure – Double tax avoidance agreement model;
3. Double tax avoidance agreement model;
4. Permanent establishment and Business Profit;
5. Tax haven countries and advance Pricing Agreement; Transfer pricing;
6. Tax Planning; Treaty Shopping, beneficial owner; controlled foreign corporation and special purpose and thin capitalization;
7. Shipping and Air Transportation;
8. Passive income and capital gain;
9. Dependent and independent personal service