Description

The internationalization of economic exchanges and the game of tax competition obliges national and international authorities to continue their fight against tax evasion and fraud. The resulting transactions and financial flows generate tax frictions, which must be identified, managed and neutralized if necessary via tax structures and solutions while limiting the risks of adjustments.

Who is this training for ?

For whom ?

Legal and tax managers, Lawyers and accountants, Tax specialists

Prerequisites

Have knowledge of business taxation or have followed “Taxation for non-tax specialists”

Training objectives

Understand the tax implications of international operations relating to transactions, incoming and outgoing cross-border financial flows, international structures, cross-border restructurings and transfer pricing

Prevent tax audit risks

Measure tax risks linked to price of transfer

Training program

• Master the applicable international taxation…
  • For transactions abroad
  • Withholding taxes on sums paid to non-resident beneficiaries
  • Taxation of sums received from the 'foreigners and tax credits
  • Recording interest received
  • Application exercise: calculation of withholding taxes on sums paid to non-resident beneficiaries
  • On the distribution of international dividends
  • The applicable tax regime
  • Methods for eliminating double taxation
  • Case study: comparative analysis of tax conventions
  • Comparison of the definitions of the concept of dividend, royalty for services
  • Comparison of methods for eliminating double taxation
  • To structures international companies
  • Branch or subsidiary, holding company: define the tax elements of the choice
  • The mechanisms for determining the tax result, reporting profits and taking losses into account
  • To cross-border restructuring operations
  • The conditions of accessibility to favorable merger regimes
  • Transfer of assets, branches of activity or purchase of securities
  • The impact of the tax situation of the seller and the buyer
  • The case of restructuring of tax-integrated companies
  • Transfer of head office outside France
  • Case study
• Manage intra-group operations fiscally
  • Treat for tax purposes international flows of dividends, interest or royalties
  • Secure invoicing for intra-group services
  • Manage international mobility of employees
  • Case study
• Anticipate tax risks in an international environment
  • Measuring the impact of the fight against tax evasion
  • The impact of articles 238 A and 209 B of the CGI
  • Identifying the concept of abuse of rights and abnormal management acts in international matters
  • Identify the most exposed arrangements
  • Take necessary precautions
  • The main risk situations
  • Managing the tax risks linked to transfer pricing
  • The arm's length principle
  • The OECD principles
  • French regulations and administrative practices
  • Methods for determining transfer prices
  • Documentary obligations
  • Resolution of double taxation
  • Case study