Events

International Taxation - Mechanisms of Tax Conventions

275 €

at 1.8 KM
House of Training Follow

Training
Business
Legislation
Strategy
Finance
Economy
Legal
Taxation

thu. 14 Nov.

Objectives

At the end of this training, the participant will be able to:
identify the fundamentals of a tax treaty
apply different techniques for the elimination of double taxation
to associate current events with the fundamental principles of international taxation

Program

Introduction
Definition of a convention
Objective of a convention
Relationship between national law and international law
Interpretation of conventions
Who benefits from a convention?
Concept of "resident" (natural person / legal person)
"Tie-breaker" rule
Concept of "person"
Special case of partnerships
Business concept
Income earned by a permanent establishment
Concept of permanent establishment
Difference between a subsidiary and a branch
Relationship between the registered office and its permanent establishment
Income determination methods
Some special cases
Notion of associated companies and its consequences
Methods of determining arm's length prices
Latest developments in Luxembourg
Treatment of capital income
dividends
Interests
Royalties - special case of know-how and services
Treatment of capital gains
Luxembourg treatment of these incomes
Treatment of employment income
Practical cases
Latest developments between Germany and Luxembourg
Double taxation elimination methods
Exemption method
Imputation method
Practical applications
Special case of information exchange
Article 26 of the model convention

Good to know

Target audience

Employees of trustees, consulting firms and law firms
Employees of banking institutions
Employees of insurance companies
Anyone already aware of the basic principles of taxation and wishing to understand the basic mechanisms of international taxation

Prerequisites

Have basic knowledge in the field of taxation.

Certificate

The course is closed by a written test whose success is sanctioned by a certificate issued by the House of Training under the authority of the Ministry of National Education, Childhood and Youth.

Course materials

The course material can be downloaded for free, the day before, via your learning portal.