Switzerland


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:

Xavier Oberson
Wolfgang Zronek
Mark Bridges
Milton Grundy
Tom O’Riordan
James Howes
Rupert Worsdale
John Rhodes

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
Tax treaties
Holding structures
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
Sham trusts

Retiring in Europe – The tax aspect

Cyprus
France
Gibraltar
Greece
Guernsey
Ireland
Isle of Man
Italy
Malta
Monaco
Portugal
Spain
Switzerland
United Kingdom

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”?

Offshore advisers:
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

Previous Spain – May 2006 Denmark – June 2006 Next

Contact one of our officers to initiate the incorporation of a Cyprus registered company and start reaping the full benefits of an onshore, low-tax, EU jurisdiction. Simply fill in the contact box below or contact us by email on enquiries@fbscyprus.com

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