Replacement schemes and direct taxes
Framework of the rules on the taxation of financial income.
The residence of investors. Tax havens and change of residence.
The principle of extraterritoriality and the taxation of non-resident subjects.
Capital income: definition, identification and determination.
The other income of financial nature: types and tax base.
The distinction between qualified and non-qualified participations: current relevance.
Taxation of capital gains.
The tax distinction between stocks, bonds and atypical securities.
The principle of attraction in the corporate income.
The withholding system: substitute taxation and withholding tax or advance payment.
The application of the levy by the intermediary.The management of the single account.
The taxation of foreign source investment income.
Tax monitoring, international conventions against double taxation, tax credit on income produced abroad.
The automatic exchange of information: focus on Fatca, Crs and Dac2. Impact on banking secrecy.
Bank and postal deposits
Government bonds and others bonds
Repurchase agreements and securities lending transactions
Individual asset management (Gpm and Gpf)
Mutual investment funds, Sicav, Sicaf, Etf, Eltif, Sis
Real estate funds
Shares and similar securities
Derivative contracts and Etc
Insurance savings: insurance policies with a financial content
Retirement pension funds and individual pension plans
Individual savings plans (Pir)
Indirect and property taxes
The substitute stamp duty: subjective and objective area, tax base, method of calculation
Tax on the value of financial products and current accounts held abroad: subjective and objective scope, tax base, method of calculation
The financial transaction tax (Tobin tax): scope of application, tax determination, exclusions and exemptions from the tax, persons responsible for the payment