17-21/06/06 in Lausanne, Switzerland
Our Directors attended the International Tax Planning Association Lausanne Meeting from 18 to 20 June 2006.
They were delighted meeting with clients and associates during their stay in Lausanne.
In case you wish to schedule a meeting with us, please Contact us.
Details on the ITPA’s Meeting:
ITPA is a multi-disciplined association of over 1000 bankers, trust officers, finance directors, accountants, lawyers and others with a practical interest in the tax aspects of cross-frontier transactions. They examine subjects mostly from the point of view of the taxpayer; membership is limited to practitioners who act for or in the interests of taxpayers.
The object of their Association is to disseminate and exchange information about international tax planning. One of the ways they do it is through their meetings / conferences.
An important feature of membership of the Association is the opportunity it offers to form contacts with practitioners in other jurisdictions. There were opportunities during each of the two days and at the receptions in the evenings to mingle with other members.
There were present:
The subjects covered in the conference include:
The Role of Switzerland in International Tax Planning
The tax system
Trusts and foundations
Holding and auxiliary structures
Recent treaty issues (new exchange of information clause, breaking treaty shopping case)
The Role of Austria in International Tax Planning
The tax system
Companies, partnerships and foundations
Royalties, financing, trading, real estate
Some Recent Trust Cases
The development of the rule in re Hastings-Bass
Its use in tax cases
Its use in place of PI insurance claims
Whether deeds to which it applies are void or voidable
Whether it applies to just one deed, or a series of deeds
Its application in different jurisdictions
Other recent cases
Retiring in Europe – The tax aspect
Isle of Man
Understanding Derivatives – Their place in tax planning
The application of derivatives: an individual’s use versus corporate use
Host jurisdictions and investments through derivative instruments
Stock lending – opportunities to mitigate liability to withholding tax
A synthetic approach to wealth management generally by way of derivative arrangements
Taxes in France – Some cautionary tales
Know your tax before you try to avoid it
Becoming resident without meaning to
Bad structures in need of dismantling
Substance over form: “genuine” vs “artificial” structures
The sting in the tail: retrospective tax assessments
International Estate Planning – A South African perspective
SA residents with offshore trusts:
What should be done post-amnesty?
Trust distributions – life gets complicated
Are “loop” structures illegal?
What about the next generation that lives overseas?
Emigrants from South Africa:
What should they do?
Frying-pan or fire? Where should they go?
Immigrants to South Africa:
Fiscal nightmare or fiscal paradise?
Is Exchange Control the “big, bad wolf”?
Proceeds of crime: a “POCA” in the eye?
Tax Amnesties – A review and some predictions
Arguments for and against tax amnesties
“Open” and “concealed” amnesties
The EU’s lost amnesty opportunity
Review of recent amnesty programmes
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