Replacement schemes and direct taxes
Framework of the rules on the taxation of financial assets.
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 equity investments: current relevance.
Taxation of capital gains.
The tax distinction between shares and similar securities, bonds and similar securities and atypical securities.
The principle of attraction in the corporate income.
The withholding system: substitute taxation and withholding tax.
The application of the withdrawal by the intermediary (banks and trustees)
Relationship between withholding agent and substitute.
The management of the single account.
The declaration regime, the administered and managed savings regime: the determination of the tax base and the obligations of intermediaries
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, Dac2 and Dac6. Impact on banking secrecy.
Indirect and property taxes
The substitute stamp duty: the managing bodies, subjective and objective area, tax base, method of calculation.
Tax on the value of financial products and current accounts held abroad (Ivafe): 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, subjects responsible for the payment
Taxation of the main financial assets
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
Real estate funds
Shares and similar securities
Derivative contracts and Etc
Insurance savings: insurance policies with a financial content
Retirement savings: pension funds and individual pension plans
Individual long-term savings plans (Pir)