This intermediate course provides an overview of the tax planning goals and objectives of a multi-national group and an in-depth discussion on the use and taxation of EU holding companies, financing and intellectual property (IP) structures in a global planning context. The course deals with specific tax planning goals and objectives and how such objectives can be achieved through the use of global and EU based holding company structures. The course addresses the tax aspects to be taken into account when establishing and dealing with holding companies in Europe, sets forth the criteria to be used in evaluating and selecting a holding company location, and offers an overview of the domestic legislation of countries that are often used as a location to establish holding companies within Europe. The course will be taught by experienced international practitioners specialised in the field of tax planning.

Day 1 of the course addresses the technicalities of the widely used EC Corporate Direct Tax Directives, the impact of ECJ and domestic case law and covers Luxembourg and the Netherlands in-depth. Day 2 provides an overview of Cyprus, Spain, and Switzerland; the use of Holding Companies for IP management activities and also covers the tax aspects to be taken into account by a US-based group in setting up its holding company in Europe. Finally, a case study session will allow participants to apply the concepts discussed during the course.

This course is ideal for in-house counsels, lawyers, tax consultants and professionals in general who wish to gain a complete overview of the taxation of holding companies, with an emphasis on certain jurisdictions, and to better understand how holding companies are utilised in a global planning context.

This is an intermediate level course. Participants should be familiar with the structure of tax treaties and their allocation rules in addition to the domestic law of at least one country, in particular as it relates to cross-border situations.
Click here for more information about the course levels.

In order to participate in this particular course, no advanced preparation is necessary. However, for some courses, suggested reading materials may be made available on our online platform a few weeks before the start of the course.

• Overview of Tax Aspects
• Applicable EC Law
• Analysis of the Domestic Legislation - Netherlands and Luxembourg
• Overview of the Domestic Legislation - Cyprus, Spain and Switzerland
• IP Management by Holding Companies
• Key Goals and Objectives for a US Multinational Group
• Case Study

(Click on the instructor's name to see the biography)

• Harry Tonino
• Regina van der Kuip
• Valery Civilio
• Kannan Raman

Recommended CPE points for this course: 12 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Click here for more information on CPE points and accreditation for ITA courses.

• Course Venue
• Accommodation and Travel
• About the International Tax Academy
• Terms and Conditions and Cancellation Policy
• General Course Information

The course fee of €1,450 covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered.
Click here for our payment details, terms and conditions and cancellation policy.