Events

Preventive double taxation agreements

220 €

Luxembourg Lifelong Learning Center Follow

Training
Politics
Standard
Legislation
Information
Finance
Legal
Taxation
Prevention
Seminar
taxe

thu. 28 May.

09h00-17h00

Target audience
This seminar is for anyone interested.

Goals
This seminar aims to deepen the themes dealt with in the seminar "Introduction to international taxation and the structuring of wealth and businesses". It covers key knowledge for advising clients (residence and change of residence, transnational taxation of direct and indirect financial and real estate products, of wealth, donations and inheritances) and the pitfalls to avoid.

Description
States, bilateral and multilateral agreements as well as supranational standards makers:
double taxation;
the origins of the OECD model convention;
cross-checking sources of tax law.
The OECD model: how to avoid double taxation?
one goal, two methods;
Luxembourgish choices.
The starting point for choosing the applicable agreements:
the residence :
natural persons;
legal persons;
resale right, exit tax and nationality;
permanent establishment, substance and reality.
The attribution of the power to impose:
examining the main sources of income;
fiscal transparency;
the wealth ;
special cases;
the examples.
Transnational successions and donations:
principles and examples.
Agreements concluded by the Grand Duchy of Luxembourg:
inventory and examples.
Inclusion or exclusion?
prevention of the abuse of conventions;
FCP, SICAVS, FIS and SICARS;
SPF and Soparfi.
Perspectives :
EU, OECD, BEPS and Co.