BB by Tributum on taxation of expats in the Czech Rep. and crossborder holding structuring


American Chamber of Commerce
in the Czech Republic


4.12.2007, 09:00 - 4.12.2007, 11:00


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At AmCham Business Briefing, Mr. Bartuška and Mr. Pomazal of TRIBUTUM CONSULTING will deliver a talk on two main topics: Holding Companies and Tax Planning, and Taxation of Expatriates in the Czech Republic, structured as follows: Holding Companies and Tax Planning in CR, EU & non-EU 1. Perfect Holding & Tax Effective Structure 2. Tax Residency – Seat vs. Place of Management 3. Debt vs. Equity Financing & Thin Cap Rules 4. Royalties (Intellectual Property - SW, Patents & TM, Know-How, Business Secret) 5. Dividends 6. Acquisition & Sale of Shares and Participations 7. Group Taxation & Profit Repatriation 8. Cross-border Reorganisation 9. Transfer Pricing Rules 10. Controlled Foreign Company (CFC) Rules 11. Reporting Trap & Effective Tax Risk Management 12. EU Common Consolidated Corporate Tax Base (CCCTB) 13. Impact of EC Primary & Secondary Law and ECJ Cases on Holding Taxation 14. Tax Effective Use of Double Taxation Conventions Network 15. Tax Effective Holding Company Placement – EU, Switzerland or going Offshore ? 16. Czech Republic – Optimal Place for (Regional) Holding? 17. Tax Planning Summary Taxation of Foreigners (Expatriates) in CR 1. Personal Taxation of Expatriates in the Czech Republic 2. Dual Residence Status 3. Tax Residency vs. Tax Non-residency in the Czech Republic 4. Taxation of Foreign Employees incl. In-kind Benefits – CZ & Foreign Incomes 5. Taxation of Foreign Managers and Directors - CZ & Foreign Incomes 6. Taxation of Business Income - CZ & Foreign Incomes 7. Taxation Passive Income (Dividends, Royalties, Interests) - CZ & Foreign Incomes 8. Controlled Foreign Company Rules (Germany, UK, USA) 9. Tax Relieves under the Czech Tax Law 10. Double Taxation Conventions Network 11. Tax Optimization Possibilities 12. Health Insurance 13. Social Insurance under Czech Law & International Treaties incl. Optimization Possibilities The speakers will respond to both general and your business-specific questions in the discussion subsequent to the presentation. Come learn how to cut your company/group‘s costs by better tax planning or tuning your managers‘ tax payments!

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