The Belgian government introduced the Caiman tax in 2015. For the uninitiated: this system aims to tax by transparency, to the personal income tax ("IPP"), the income collected by certain foreign "legal constructions" (trusts, low taxed foreign companies, certain insurance contracts ) in the head of their "founders", as if the latter had directly received the income of said structures. Very quickly, we began to doubt its effectiveness, because this diet had many flaws.
During this training, the speaker will focus on examining the possible application of the cayman tax to two Luxembourg "products":
the Luxembourg holding company, also known as SOPARFI ("Financial participation companies"). This vehicle has a real fascination with many Belgian residents. To be convinced of this, we can refer in particular to the recent LuxFiles survey, which revealed that the hundred wealthiest Belgian families had housed assets of around 48 billion euros in SOPARFIs.
Luxembourg life insurance products in branch 23, whether or not linked to dedicated funds.
The speaker will add many practical examples to his presentation. He will share his rich practical experience in this area, and in particular the approach adopted by the Belgian tax administration in specific cases (in the context of notices of rectification). He will also discuss the arguments that may be invoked by taxpayers in the context of a tax procedure (annoyance with the constitutional principle of equality, annoyance with the free movement of capital, annoyance with the Belgian-Luxembourg preventive agreement, etc.).
The training is intended for practitioners of Belgian and Luxembourg taxation.
Good to know
Price: 195 € HTVA
Student rate: € 48.55 excl. VAT, i.e. € 50 incl. Tax (provided you send a copy of your student card and a registration certificate)
Automagically translated from French
Organizer
Legitech
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