Certification in International Taxation in the Post-BEPS era

The global consensus on the International Taxation basic pillars has been rigorously questioned and analyzed by the OECD (Organization for Economic Cooperation and Development) for the past seven years.

In July 2013, the BEPS Action Plan, containing 15 proposals, was launched to define the tools to combat tax base erosion and profit shifting.

In 2015, the final reports came to light, with recommendations for the modification of internal laws which, in Colombia, were taken into account by Laws 1819 of 2016 and 1943 of 2018. Also, the reports established new standards for the negotiation of Double Taxation Agreements, reflected in OECD Model 2017, and that have impacted the treaties recently negotiated by Colombia.

Finally, the BEPS Action Plan 15 brought guidelines for the elaboration of a multilateral instrument allowing the implementation of the recommendations, swiftly and efficiently, on the existing agreement network. On the latter, the OECD worked with several countries, and on September 7, 2017, the Multilateral Convention to Prevent Base Erosion and Profit Shifting” was signed, with the promise to “fill regulatory gaps and the legal vacuum experienced in thousands of tax agreements worldwide.”

The Certification aims to recognize these changes and spread its reach in Colombia, and at the same time create a critical space for discussion and measurement of their effects, for taxpayers and tax advisors, as well as the tax administration. International Tax Law has changed, and this course seeks to show how these changes have affected and will affect the Tax Law practice.

The event features participation by the following professors, experts in International Taxation:

1. Olga Lucia González

2. José Manuel Castro

3. Mauricio Marín Elizalde

4. Camilo Zarama

5. Laura Sanint

6. José Galindes

7. Pablo Hernández

8. Carlos Giovanni Rodríguez

9. María Helena Bocachica

10. Julián Moreno

11. Irma Mosquera

* The Department may change the teaching faculty without advance notice.

The following topics will be addressed:

1. Introduction to BEPS and the international aspects of the 2017 Reform

2. Permanent establishment

3. Harmful tax practices

4. Hybrids

5. Entities controlled abroad

6. Financial expenses

7. Transfer pricing (introduction, methods, general review, intangibles and risks, Colombian jurisprudence, and BEPS implementation in Colombia)

8. Indirect sale of assets

9. Digital economy

10. IFRS and their impact on international taxation

11. MLI and new 2017 OECD Model: abuse

12 BEPS Plan effects on multi-Latins

13. Global Forum on transparency and exchange of information

14. Tax planning: limits and schemes disclosure

15. Exchange of information: dispute resolution mechanisms

Program schedule: