Canada’s international tax framework is highly complex, underpinned by an extensive network of more than 90 tax treaties, cross-border transactions, transfer pricing, withholding taxes, and international corporate structures. Multinational organizations must also contend with the OECD’s Base Erosion and Profit Shifting framework, the Global Minimum Tax, Canada’s General Anti-Avoidance Rule (GAAR), Foreign Accrual Property Income (FAPI) provisions, and evolving disclosure requirements.
This certified program will give you a comprehensive command of Canadian international tax regulations and equip you to structure tax-efficient cross-border operations, investments, financing arrangements, and corporate transactions. With a strong emphasis on practical application, it enables you to address transfer pricing compliance, permanent establishment risks, withholding tax exposure, foreign affiliate taxation, treaty interpretation, and anti-avoidance requirements with confidence. You will gain a detailed understanding of international tax planning principles, double tax treaties, FAPI rules, surplus calculations, intellectual property structuring, and cross-border financing strategies.
Throughout the program, you will build critical capabilities in international tax structuring, compliance management, transaction planning, and tax risk assessment. The course delivers expert insights into transfer pricing documentation, treaty entitlement, repatriation planning, foreign tax credits, hybrid arrangements, and the application of Canada’s GAAR and mandatory disclosure rules. It also explores best practices for structuring acquisitions, holding companies, financing arrangements, supply chains, and intellectual property ownership. Through interactive case studies and practical examples, you will gain hands-on experience evaluating cross-border structures, resolving complex tax challenges, and developing defensible international tax strategies.
Upon successful completion, you will earn the Certification in Canada International Tax Planning and Structuring, a distinguished lifelong credential that affirms your ability to assess international tax risk, evaluate cross-border structures, and drive informed, commercially sound corporate decisions.
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This program will entitle you:
Download Brochure Pricing & Registration- Engage in 2 days of intensive, expert-led training that strengthens your ability to defend complex cross-border tax positions through transfer pricing documentation, audit readiness and Advance Pricing Arrangement (APAs)—equipping your organization to respond decisively to Canada Revenue Agency (CRA) scrutiny and international tax disputes
- Earn the Certification in Canada International Tax Planning and Structuring, a lifelong credential demonstrating your capability to manage multinational tax complexity, strengthen governance and support effective cross-border investment decisions.
- acquired or multinational operations are reorganized.
- Stay ahead of the international tax rules reshaping multinational structures, including BEPS, the MLI, PPT, and Pillar Two, and translate evolving requirements into stronger tax governance, more defensible planning, and tighter alignment between tax strategy and business objectives.
- For inquiries, chat with our Program Advisors at [email protected] or call us at
- Singapore and Asia Pacific: +65 6716 9980
- Australia and New Zealand: +61 3 9909 7310
- UK, Europe and Middle East: +44 (020) 335 57898
- Canada: +1 833 879 8820
- USA: +1 888 745 8875
Accreditations
This program is accredited by the Chartered Institute of Professional Certifications, the body that sets and upholds the governing standards for every professional who completes it.
The content of this program has been fully certified and accredited by CPD Certification Service as conforming to Continuing Professional Principles. CPD is the leading independent CPD accreditation institution operating across industry sectors, complementing the Continuing Professional Development policies of professional institutes and academic bodies. The CPD Certification Service provides support, advice, and recognized independent CPD accreditation compatible with global CPD principles.
What Can You Expect From This Live Program
Canada’s international tax landscape has entered its most demanding phase yet, with 94 tax agreements in force, 50 meeting the OECD’s treaty anti-abuse minimum standard, and a 15% global minimum tax now applying to qualifying multinational groups. For tax, finance, and legal professionals, the stakes have never been higher: where profits are taxed, how structures are designed, and whether cross-border positions can withstand regulatory scrutiny. Connecting technical tax rules with commercial decisions is no longer optional—it is a strategic imperative.
This certified program equips you with the practical expertise to navigate Canada’s international tax system and make sharper cross-border business decisions. You will build authoritative command of Canadian tax residency, treaty planning, and permanent establishment rules, enabling you to pinpoint where tax obligations arise and when treaty relief applies. You will also master how to evaluate inbound and outbound investment structures, foreign affiliate rules, and FAPI implications, so you can establish, finance, and manage international operations with greater tax efficiency, full compliance, and commercial confidence.
The program then focuses on the international tax decisions with the greatest commercial impact. You will apply transfer pricing principles, assess cross-border financing, and evaluate M&A tax considerations to support defensible transactions and investment decisions. You will also examine profit repatriation, corporate reorganizations, and anti-avoidance risk, enabling you to detect exposure early. Coverage of BEPS, the MLI, and Pillar Two will sharpen your ability to assess evolving multinational tax obligations. By connecting tax expertise with commercial priorities, you will be fully equipped to protect transaction value, drive cross-border growth, and contribute strategically to investment decisions.
Upon successful completion, you will earn the Certification in Canada International Tax Planning and Structuring. This distinguished lifelong credential is a powerful testament to your ability to identify international tax risks earlier, challenge structuring assumptions with authority, and bring sharper tax insight to strategic investment and corporate decisions.
Key Skills You Will Gain
- Canadian International Tax Framework
- Tax Residency Analysis
- Source Rule Interpretation
- Tax Treaty Application
- Treaty Residence Analysis
- Permanent Establishment Assessment
- Beneficial Ownership Analysis
- Treaty Relief Planning
- Treaty Shopping Risk Assessment
- Inbound Investment Structuring
- Entity Selection Analysis
- Debt-Equity Structuring
- Outbound Investment Planning
- Foreign Affiliate Analysis
- FAPI Assessment
- Surplus Regime Planning
- Foreign Earnings Analysis
- CRA Audit
- Withholding Tax Planning
- Foreign Tax Credit Planning
- Double Taxation Relief
- Transfer Pricing Analysis
- Arm’s-Length Principle Application
- Transfer Pricing Method Selection
- Functional Analysis
- Transfer Pricing Documentation
- Country-by-Country Reporting
- Advance Pricing Arrangements
- Mutual Agreement Procedures
- Cross-Border Financing Analysis
- Thin Capitalization Assessment
- Pillar Two Analysis
Your Faculty Director
Natalie Yunes is a seasoned tax executive with over 20 years of experience managing tax functions for global organizations. She currently serves as Director of Tax at Sanofi Pasteur, where she oversees Canadian tax compliance, audit management, and strategic planning. Prior to this, she held senior tax roles at Bayer and began her career at KPMG, gaining extensive expertise in corporate tax reporting, transfer pricing, international tax compliance, and cross-border transactions.
Natalie has led numerous tax audits, guided complex reorganizations, and advised on acquisitions and divestitures. A long-standing member of the Tax Executives Institute, she is recognized for her in-depth understanding of federal and provincial tax legislation, and her ability to translate complex regulations into actionable strategies. A respected speaker and educator, Natalie has presented for Federated Press, Financial Executives International, the Tax Executives Institute, and KPMG’s Consumer Market Forum.
Canada International Tax Planning and Structuring Program Agenda
How You Will Benefit
- Master Canada’s International Tax Architecture: Develop authoritative command of the Canadian international tax framework governing cross-border investment, corporate structures, financing arrangements, and multinational operations.
- Design Tax-Efficient Cross-Border Structures: Evaluate and structure inbound and outbound investments to optimize tax outcomes while maintaining alignment with Canadian statutory, treaty, and anti-avoidance requirements.
- Strengthen Transfer Pricing Governance: Apply advanced transfer pricing principles to intercompany transactions, documentation, functional analysis, and pricing methodologies to support technically robust and defensible tax positions.
- Navigate Treaty and Permanent Establishment Exposure: Interpret Canada’s tax treaties, assess treaty entitlement, and identify permanent establishment risks to determine taxing rights, available relief, and cross-border compliance obligations.
- Master Foreign Affiliate and FAPI Regimes: Analyze Canada’s foreign affiliate system, Foreign Accrual Property Income rules, surplus accounts, and repatriation mechanics to manage the taxation of offshore investments and earnings.
- Optimize Cross-Border Financing and Repatriation: Assess debt and equity financing structures, withholding tax implications, foreign tax credits, hybrid arrangements, and profit repatriation strategies to enhance after-tax efficiency.
- Structure International M&A and Reorganizations: Evaluate the Canadian tax consequences of acquisitions, divestitures, corporate reorganizations, holding structures, and cross-border transactions to preserve transaction value and mitigate tax leakage.
- Evaluate Intellectual Property and Global Supply Chain Structures: Assess the tax implications of intellectual property ownership, licensing models, supply chain arrangements, and international operating structures within an evolving global tax environment.
- Manage Anti-Avoidance and Disclosure Risk: Apply Canada’s General Anti-Avoidance Rule, mandatory disclosure regime, and related anti-avoidance provisions to identify aggressive tax positions, manage exposure, and strengthen governance.
- Navigate BEPS, MLI, and Pillar Two Developments: Evaluate the impact of BEPS initiatives, the Multilateral Instrument, and Pillar Two global minimum tax rules on multinational structures, compliance obligations, and strategic tax planning.
Certification in Canada International Tax Planning and Structuring
Upon successful completion of this program, you will be awarded the Certification in Canada International Tax Planning and Structuring, a lifelong credential you can showcase on your resume, CV, and professional profile as proof of your specialist capability in managing complex cross-border tax matters, evaluating international structures, and navigating evolving Canadian tax requirements.
This certification is a powerful testament to your command of the tax principles, structuring considerations, compliance obligations, and risk management practices that shape Canadian international taxation—strengthening your credibility to support informed, compliant, and commercially sound cross-border decisions. The program is developed by the Chartered Institute of Professional Certifications, the program content has been independently accredited by CPD Certification Service as conforming to Continuing Professional Development principles.
Pricing & Registration
Canada
Dates: 6 - 7 May 2027
Venue: Online Executive Program (via Zoom)
Time: 8:00am - 3:30pm Pacific Time (PT)
10:00am - 5:30pm Central Daylight Time (CDT)
11:00am - 6:30pm Eastern Daylight Time (EDT)
| Early Bird Packages | Regular Pricing | ||
|---|---|---|---|
| By 26 Feb 2027 | By 09 Apr 2027 | After 09 Apr 2027 | |
| Canada Delegates | CAD 1,895 | CAD 2,195 | CAD 2,295 |
Group Discount: 2nd participant get 10%, or register 3 participants and 4th participant get a complimentary seat (1 discount scheme applies)
Register NowDownload Brochure
You can download our program brochure below. For any inquiries about this program, please contact our Program Advisor at [email protected] or call us at:
- Singapore and Asia Pacific: +65 6716 9980
- Australia and New Zealand: +61 3 9909 7310
- UK, Europe and Middle East: +44 (020) 335 57898
- Canada: +1 833 879 8820
- USA: +1 888 745 8875
Convincing Your Boss To Attend This Program
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Canada International Tax Planning and Structuring
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