Application of tax treaties

The MCCI Business School is organising a course on double taxation treaties to provide a better understanding of its practical application. The course is designed to guide participants with the application of the different articles of the OECD Model double taxation treaty together with the Commentary of the OECD on the interpretation of the model tax treaty.

Courses will be conducted by Mr Kader Mungly, Tax Consultant, Chartered Accountant, M Com. (South African and International Taxation), and MTP (SA). The course is MQA approved and is refundable by the HRDC. A certificate of attendance will be awarded to the participants.

Who should attend: Course Content:

Courses Fees : Rs 25,000
CPD : Attendance will secure verifiable CPD 12 hours
Venue : MCCI Business School, Ebène Tel 454 8950 Fax 454 8960 Email :

07th June 2016 09H00 – 12H30
Session 1

1. Overview of tax treaties
2. Entitlement to tax treaty benefits
3. Income from immovable property and capital gains
4. The Preliminary definition of Permanent Establishment (PE) para. 1 & 2
Case studies Module 1 to 4
Q&A Module 1 to 4

14th June 2016 09H00 – 12H30
Session 2

5. PE – Multiple places of business para. 3 to 7
6. Business Profits – Income attributable to a PE
7. Tax issues relating to Electronic Commerce
8. Independent Personal Services
9. International Shipping and Air Transport
10. Adjusting income of associated enterprises & Mutual Agreement Procedures
Case studies Module 5 to 10
Q&A Module 5 to 10

21 June 2016 09H00 – 12H30
Session 3

11. Dividends/Partnership Share
12. Interest and Thin Capitalisation
13. Royalties, Equipment, Leases, Software, Know How, Satellite and Broadcast Payments
14. Income from Employment, Students and Teachers
15. Directors, Diplomats and Government Services Case studies Module 11 to 15
Q&A Module 11 to 15

28 June 2016 09H00 – 12H30
Session 4

16. Entertainers and Sportsmen
17. Pensions
18. Other income and final provisions
19. Elimination of double taxation
20. Exchange of Information
Case studies Module 16 to 20
Q&A Module 16 to 20

Copyright © 2017 MCCI Business School