Day one: March 18th, 2008
09:00 Chairman?s welcome & opening remarks
Dr Ludovic Verbist (Switzerland)
Managing Director
AAMIL Ltd
09:10 Introduction
- Offshore: the concept
- Where to find it?
- Case by case
- Confidentiality, political stability
- Within or outside of the European Union
Dr Ludovic Verbist (Switzerland)
Managing Director
AAMIL Ltd
09:55 Quo vadis offshore financial service centers
- A description of how the offshore financial markets are expected to develop during the next few years
- Who are the major players in this market segment and who are the future players?
Mr Jean-Pierre Diserens (Switzerland)
Co-founder, vice-chairman and executive vice-president
Convention of Independent Financial Advisors (CIFA)
10:40 Coffee break
Residency
11:00 Belgium as an ideal residence country for high net worth individuals
- Absence of wealth tax, no capital gains taxation, personal investment income taxed at flat rates
- Tax planning opportunities
- Belgian foundations, international income tax planning opportunities
Mr Patrick Vanhaute (Belgium)
Tax Lawyer
Patrick Vanhaute Advocaat
11:25 Residency in Mauritius
- GBL1 work permit
- Investment of US$ 500,000
- As retired
- Purchase of IRS
- Different tax situations
Mrs Cécile Civiale Vuillier (Switzerland)
Relationship Manager
AAMIL Ltd
11:45 Residency in Monaco
To be confimed by the programme manager
Mr Xavier Périnne (France)
Attorney at Law
Perinne Ribierre Redding
12:05 Residency in the United Kingdom
- Residence - the statutory rule and the extended
- Residence and domicile and the significance scope with reference to practice and case law (IR20) thereof in the context of the direct taxes
- The position post 'Gaines-Cooper'
- The remittance basis and the developments proposed post the 2007 Pre Budget Report
- Ordinary residence and earned income
Mr Tom Meadows (United Kingdom)
Partner
Steele Robertson Goddard
12:30 Lunch
Trading companies
14:00 Trading companies in Luxembourg
- Forms of commercial companies
- Business permits
- Tax issues
- Social securities issues
Mr Bernard Felten (Luxembourg)
Attorney at Law
Felten & Associates
Mrs Renat Josten (Luxembourg)
Economist - Tax consultant
Felten & Associates
14:25 Trading companies in Mauritius
- The IBC type structure
- Tax issues
- Operational aspects
- Control and management
Mrs Cécile Civiale Vuillier (Switzerland)
Relationship Manager
AAMIL Ltd
14:50 Trading companies in the United Kingdom
- Incorporation and compliance
- Trading with as opposed to within the UK
- Central control and management
- Permanent establishments
- Inward investment into the UK (including the corporate venturing scheme)
- E-Commerce
Mr Tom Meadows (United Kingdom)
Partner
Steele Robertson Goddard
15:15 Coffee break
Life insurance
15:40 Private bank insurance products versus financial products (qualification issues)
- Tax planning opportunities
- Inheritance tax aspects
- New trends and case law
Mr Patrick Vanhaute (Belgium)
Tax Lawyer
Patrick Vanhaute Advocaat
16:20 Life insurance in France
To be confimed by the programme manager
Mr Xavier Périnne (France)
Attorney at Law
Perinne Ribierre Redding
17:00 Chairman's closing comments
17:15 Cocktail
Day two: March 19th, 2008
09:00 Chairman?s welcome & opening remarks
Dr Ludovic Verbist (Switzerland)
Managing Director
AAMIL Ltd
Holding regimes
09:10 Use of Belgian holdings for private wealth management
- Advantages/disadvantages
- Impact of the national interest deduction (NID)
- Case by case
- Withholding tax aspects
Mr Patrick Vanhaute (Belgium)
Tax Lawyer
Patrick Vanhaute Advocaat
09:20 Panama - 80 years serving the offshore asset protection industry
- Tax havens at a Critical Point
- Offshore financial centres
- Offshore structures
- Offshore foundations and trusts
Mr Rogelio Tribaldos-Alba (Panama)
Founder & CEO
MMG Panazur Ltd
09:30 Holding regime in the United Arab Emirates
To be confimed by the programme manager
Mr Georges Johnson (United Arab Emirates)
Manager; Legal Department, Government of Ras Al Khaimah
Government of Ras Al Khaimah
09:40 Holding regime in Luxembourg
Mr Bernard Felten (Luxembourg)
Attorney at Law
Felten & Associates
Mrs Renat Josten (Luxembourg)
Economist - Tax consultant
Felten & Associates
09:50 Holding regime in the United Kingdom
- Transfer pricing
- Thin capitalisation
- Cross-border tax arbitrage
- The effect of withholding taxes
- CFC' s
- Relief for substantial shareholding
Mr Tom Meadows (United Kingdom)
Partner
Steele Robertson Goddard
10:05 Holding regime in Mauritius and Seychelles
- GBL1 company
- Double taxation agreements
- Tax issues
- Examples of uses
Dr Ludovic Verbist (Switzerland)
Managing Director
AAMIL Ltd
10:20 Main aspects of the Dutch holding regime
- The participation exemption, which exempts dividends and capital gains received from qualifying participations
- No or low withholding tax rates on incoming and outgoing dividends, as a result of the EU Parent/Subsidiary Directive and the approx. 80 tax treaties concluded by the Netherlands
- Absence of withholding tax on outgoing interest and royalties
- Possibility of tax reporting in the group?s functional currency (like USD or GBP)
- An advance tax ruling system
- Excellent infrastructure
Mr Auke von der Horn (Netherlands)
Tax Lawyer
CMS Derk s Star Busmann
10:30 Coffee break
Investment funds
10:50 Investment funds in Mauritius
- Setting up
- Conditions to fulfill
- Practical considerations
Dr Ludovic Verbist (Switzerland)
Managing Director
AAMIL Ltd
11:35 Main aspects of the two regimes for investment institutions: the "VBI regime" and the "FBI regime"
- Both regimes: exempt from corporate income tax
- VBI introcuded as of 1 August 2007
- FBI recently changed, now also available for foreign companies
- Requirements of both regimes
- Differences between both regimes
- FBI in particular attractive for investing in Dutch real estate
- VBI in particular attractive for investing in financial instruments
Mr Auke von der Horn (Netherlands)
Tax Lawyer
CMS Derk s Star Busmann
12:20 Lunch
Trademarks, royalties, patents
14:00 Trademarks, royalties, patents in Mauritius
To be confimed by the programme manager
M Alexandre Weith (Switzerland)
Attorney at Law
Etude Bugnion
14:30 Intellectual property rights: how to own them and to exploit them in a most tax efficient way
- General considerations concerning IP Rights and taxation - mainly with respect to ownership location
- Vehicles for ownership or for carrying and using the IP Rights (licensing)
- Tax considerations (avoidance of pitfalls)
- Practical examples of tax efficient structures
Dr Kamen Troller (Switzerland)
Of counsel
Lalive Attorneys
15:00 Coffee break
Tax planning
15:15 Topic to be confirmed
Mr Patrick Vanhaute (Belgium)
Tax Lawyer
Patrick Vanhaute Advocaat
Mr Tom Meadows (United Kingdom)
Partner
Steele Robertson Goddard
16:10 Why tax planning?
- Internationalisation of business and investments
- How to approach it?
- EU directives, Double Taxation Agreements and regional (enter State) agreements
Dr Ludovic Verbist (Switzerland)
Managing Director
AAMIL Ltd
17:00 Chairman's closing comments
17:15 Close of the conference
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