INTERNATIONAL FISCAL POLICY I Olivier BEDDELEEM [email protected].
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Transcript of INTERNATIONAL FISCAL POLICY I Olivier BEDDELEEM [email protected].
Introduction
• Taxation in a global environment
PART 1 : TAXATION OF PRIVATE PEOPLE
• 2 possibilities : – The countries did not sign a tax convention– The countries signed a tax convention
SEMINAR 1 : French Taxation of International Revenue
I- Taxation of French residents
• A- Definition of a French resident– 1) Residence and nationality
– 2) Criteria for residence– Alternative criteria
• Home
• Main residence
• Business activity
• Center of economic interests
• B- Taxed revenues– 1) Principle
– 2) Exceptions : exemptions– Total exemption
• General rule
• Certain activities
– Partial exemption
II- Taxation of non-residents
III- Double taxation
SEMINAR 2 : The OECD model tax treaty
I- The signature of a tax treaty
• A- What is a tax treaty ?
• B- Why sign a tax treaty ?
II- The OECD model tax treaty
III- The determination of the fiscal residence
IV- Taxable revenues
• A- Scope of the OECD treaty
• B- Repartition of taxable revenues between the countries
Seminar 3 : Prevention of double taxation
Introduction : Why isn’t repartition enough ?
I- Exemption
• What is exemption ?
• A- Total exemption
• B- Partial exemption
• C- Partial exemption in OECD treaties signed by France
II- Credit
• What is a credit ?
• A- Total credit
• B- Partial credit
• C- Fictive credit