All these aspects impact corporation tax systems and the taxation of income from capital and have an influence on the determination of profits for tax purposes. Activities of international groups necessitate a reengineering of group taxation and the creation of cross-border enterprise structures. Different corporate income tax systems will be analyzed and compared in a contrastive manner. Issues of taxable entities as well as acknowledging foreign legal organizational forms as well as differences in the taxable base, the profit determination for tax purposes and the options for forming reserves and provisions are discussed. This lecture is rounded off by a comparison of the different systems of group taxation.
Trusts play a central role in both national and international tax planning.
Their use for international tax planning purposes has spread from English-speaking common law countries to continental civil code jurisdictions and ratification by many countries of the Hague Convention on the Law Applicable to Trusts and on their recognition has led the growing use of trusts in civil law jurisdictions. This course explains the trust concept to civil law practitioners and reviews the tax regimes applied to trusts in common law jurisdictions. It provides a useful guide to tax considerations governing the use of trusts for investment in these jurisdictions and the tax implications of trust investments from common law jurisdictions to civil law jurisdictions.