Selected tax systems
Anti-avoidance measures Tax law of the EU Tax treaty law International tax planning International tax policy Supplementary courses Master's thesis 
 
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International tax planning (18) |
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Principles of International Tax Planning (1,5) International tax planning has gained a lot of attention from both the perspective of taxpayers and tax authorities. This lecture deals with the building blocks of international taxation, such as the concept of permanent establishment and the arm's length principle, as applied for international tax planning purposes. It focuses on the boundaries between legitimate tax planning, tax avoidance and tax evasion, by analyzing relevant case law. Finally, it deals with some tax planning schemes for multinational enterprises.
F 10/11: October 29, 2010
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Tax Planning in France (3) This lecture introduces individual and corporate taxation under French domestic tax laws. Special issues such as the taxation of foreign and domestic entities subject to special tax regulations are addressed. Furthermore, this lecture covers mergers and taxation of groups, international taxation, taxation of foreign income to domestic recipients and taxation of domestic income to foreign recipients, as well F 09/10: May 14-15, 2010 as procedural issues, reporting and the exchange of information.
F 09/10: May 14-15, 2010
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The lecture will be a broad-based discussion of U.S. tax issues, both from an inbound and outbound perspective. The first day will address inbound matters, including withholding taxes on portfolio income, net income taxation of permanent establishments, branch taxes, hybrid financings, and related treaty issues. The second day will concentrate on transfer pricing.
F 09/10: April 30-May 1, 2010
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Tax planning always requires extensive knowledge of a country's tax system. International tax planning, moreover, also requires some knowledge of the tax systems of different countries, in order to enable the structuring of tax-efficient international arrangements. Considering this need, the lecture aims to provide an overview of the tax systems of the South American countries. The Brazilian case will be taken as the main example for discussions focused on value added and direct taxation, as well as tax treaty policy. Opportunities for tax planning on income taxation can arise from the adequate use of tax treaties between the Latin American and European countries, especially considering the massive presence of the matching credit mechanism in those treaties. Knowledge of the existence and the correct application of such mechanisms can be a valuable tool when deciding on investment and business structures involving South America.
F 10/11: April 15-16, 2011
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Many of the names of Japanese companies are all too familiar. The business and tax environment in Japan, however, remains a mystery to many people living outside Japan. To bridge the gap, this course introduces the basic structure of Japanese income taxation, and examines some of the recent tax controversies involving international transactions.
F 09/10: May 7-8, 2010
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This course reviews the basic policy and doctrinal principles relevant to the income tax treatment of financial instruments in a cross-border context. The course begins with a discussion of the general tax policy principles and financial market theories relevant to the income tax treatment of financial instruments. Students are introduced to the basic analytical concepts that are common to all financial instruments, including debt, equity and derivatives. After reviewing this introductory material, the course focuses on the income tax issues raised by the cross-border use of financial instruments. Topics covered include: (i) avoidance of non-resident withholding tax; (ii) thin capitalization; (iii) international tax arbitrage transactions; and (iv) application of tax treaties to derivative financial instruments.
F 09/10: March 19, 2010
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Tax planning in international companies is an integral part of business planning and depends in its scope and priorities on the business models employed, the global footprint structure, etc. as well as the tax management and risk approach; it is also influenced by the company's legal structure and headquarters/holding domicile. This lecture aims at addressing general aspects of tax planning in international companies, using case studies dealing with intra-group services (in the area of management, group functions and IT/IS), intra-group financing issues, the organization and funding of research & development activities and the tax aspects of trademarks (marketing intangibles). Transfer pricing documentation is a contentious issue in practice and is thus discussed in some depth. Local tax laws, and EU tax law as well as tax treaty law, have to be considered in the tax planning activities of companies.
F 10/11: April 29-30, 2011
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The use of holding companies has been gaining importance in international tax planning. Additional or reduced tax burdens can result from mezzanine holding structures, which also results in specific corporation tax difficulties. This lecture aims at describing the decisive structural and location factors. The management of intra-group income transfers, repatriation and allocation strategies, as well as viable combinations are considered as options. Vital holding locations are described in more detail. Tax treaties are relevant for the use of holding companies, as they may not be eligible for advantages arising from such treaties
F 09/10: May 28-29, 2008
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Qualification conflicts arise when two countries assess an international case in different ways. Here, it is first necessary to clarify how the double taxation convention deals with qualification conflicts. However, the lecture should focus on how qualification conflicts may thus be used to generate tax advantages within the framework of international tax planning. First of all, the basic procedure for the handling of qualification conflicts is developed. Subsequently, the considerations F 09/10: June 11, 2010 are applied to practical cases.
F 09/10: June 11, 2008
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Since the 1960s, the contribution of general consumption taxes to the tax revenues of the OECD Member States has grown from about 12% to 18%. With the exception of the USA, all OECD Member States (and many non-OECD countries) apply a value added tax-type consumption tax, levied throughout the production and distribution chain of goods and services. Cross-border transactions of goods and services (within multinational concerns or between independent parties) have increased as a result of growing mobility and globalization. Although the final consumer should bear the burden of VAT, business and industry are both taxable persons and tax collectors. Deficiencies in national consumption taxes systems have become major obstacles for enterprises engaged in international business and may lead to double or non-taxation. The lecture focuses on providing the necessary understanding of international aspects of consumption taxation in general and the VAT system in particular. VAT planning possibilities and new developments in EU VAT policy will be discussed.
F 10/11: February 25-26, 2011
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Globalization has largely increased the number of international mergers and acquisitions. This lecture aims at providing a comprehensive analysis of the tax aspects of such transactions both from the perspective of the seller and the purchaser. Topics to be addressed include the structuring of M&A transactions, financing aspects, continuing utilization of loss carry-forwards and indirect tax costs.
F 09/10: March 20, 2010
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Tax treaties are very important tools in international tax planning. Parallel to the increase of cross-border transactions, more and more questions about the interpretation of specific tax treaty provisions are raised. When attending this lecture, students will already have dealt with principles of tax treaty law and with a lot of other issues of international tax law. With that knowledge in mind, they will deal with even more sophisticated issues of international tax law that play an important role in international tax planning.
F 09/10: June 18-19, 2010
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c/o Academy of Public Accountants,
A 1121 Vienna, Schönbrunner Strasse 222-228/1/6/3