The purpose of this MBA is to provide knowledge of Tax Management (public and private perspective) and Tax Compliance of Tax Divisions of Inter-American and Euro-American Corporate Groups, as well as the Management of Tax Administration Bodies in America and Europe. The program offers a factual approach to publicize and analyze the different tax regimes that affect inbound and outbound reciprocal investments in America and Europe, including different vehicles most used in financial practice such as Investment Funds, Private Equity Funds, Hedge Funds, Trusts, Securitizations, Insurance with Investment Underlyings, Autonomous Investment Equities, Foundations, Holdings, and more, all from the 'Base Erosion and Profits Shifting' perspective of the OECD.
Highlights
Content delivered in English, Portuguese and Spanish
4 thematic units covering Transfer Pricing, Tax Planning, BEPS/OECD Treaties, and Compliance
100% Online, Synchronous and asynchronous sessions
Professors from 12 countries across Americas and Europe
Specialist certificate issued by FBT, Faculdade Brasileira de Tributação
Target audience
Vice Presidents of Companies, CFOs, Corporate Officers and Tax Managers, Lawyers, Accountants, Compliance Officers, Directors, and Board Members / Members of Tax Administration Departments.
Curriculum
Global Transfer Prices
Analyze specific cases of transfer prices to understand their practical application in different international contexts.
Study Tax Rulings and tax reports to understand how transfer pricing rules are interpreted and applied.
Review jurisprudence, both administrative and judicial, and leading cases to identify precedents and their influence on transfer pricing regulations.
Develop a solid understanding of compliance obligations related to Transfer Pricing, ensuring regulatory compliance.
Practical case: Analysis of jurisprudence and/or reports from the tax administrator body to apply knowledge acquired in real situations.
Non-Aggressive Tax Planning with Applied BEPS Approach
Identify when tax planning practices are not considered aggressive according to global courts, in line with BEPS principles.
Develop Tax Planning strategies for Family Offices and global investments without resorting to tax havens.
Evaluate investments in variable income (shares) and fixed income (bonuses), as well as hybrid financial contracts, ensuring a responsible fiscal approach.
Analyze the use of hybrid entities, such as Mutual Investment Funds, Trusts and fideicomisos, in the context of tax planning.
Explore hybrid financial products and their tax treatment.
Understanding the taxation of Merger & Acquisitions (M&A) processes with an aggressive focus.
Practical case: Analysis of jurisprudence (administrative and/or judicial) and/or Tax Rulings (reports from the tax administrator body) to apply knowledge in real scenarios.
Treaties, BEPS/OECD Agreements applicable to investments, US TARIFFS, Holdings - Pillar 2 BEPS/OECD and Tax Arbitrations
Evaluate which countries have signed the Multilateral Anti-BEPS Treaty and analyze the implementation of unilateral norms in countries that have not signed it.
Analyze the effects of the Global Information Exchange Treaty and determine the impact on countries that have signed these agreements.
Examining the global effects of US Tariffs and their impact on global taxes and BEPS/OECD regulations.
Understand the current state of Pillar 2 and the Global Minimum Impuesto and analyze the best location to establish holdings under these regulations.
Explore global tax arbitrations and their role in resolving international tax disputes.
Analyze the role of special zones and free zones in light of BEPS/OECD regulations.
Practical case: Applied real consultancy and trend analysis in real inspections implemented to apply knowledge acquired in real world situations.
Compliance in Outbound & Inbound
Analyze the use of derivative financial instruments, financial hybrids, CFCs ("Controlled Foreign Corporations") and M&A vehicles in inbound and outbound operations.
Understanding the characteristics of PFICs ("Passive Foreign Investment Company") and their impact on international taxation.
Evaluate the tax implications of the indirect sale of shares in a global context.
Develop strategies for fiscal control of intercompany tax planning, ensuring regulatory compliance.
Explore methods of repatriation of funds and associated tax considerations.
Understand the operation of the Foreign Tax Credit and its application in mitigating double taxation.
Know the duration of the residence certificate and other basic compliance rules to guarantee tax compliance.
Practical case: Analysis of jurisprudence and/or reports from the tax administrator body to apply knowledge in real situations.
Countries
Peru 🇵🇪, Brazil 🇧🇷, Argentina 🇦🇷, Colombia 🇨🇴, Panama 🇵🇦, Mexico 🇲🇽, United States 🇺🇸, Canada 🇨🇦, Germany 🇩🇪, Italy 🇮🇹, Spain 🇪🇸, United Kingdom 🇬🇧