INTERNATIONAL FISCAL POLICY I

Olivier BEDDELEEM

Beddeleemo@gmail.com

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