Saturday, 17.07.2010
9h - Introduction
Professor/Lecturer: Lic. iur. Roland A. Pfister, EMBA
Objective
Course contents and structure of the seminar
Swiss Tax Law System in a nutshell
-The Place of Effective Management in Tax Planning
-Exchange of information with regard to Tax Evasion and Tax Avoidance -Liechtenstein Tax Reform and Strategie compared to the Tax Strategie of Switzerland – in a nutshell
Introduction to DTCs
-Classification of International Tax Law
-Effects of DTCs
-History of the DTC between Switzerland and Argentina
-Direct and indirect objectives of DTCs
-Legal nature of DTCs
-Structure and mechanism of DTCs with particular
reference to the OECD Model in comparison to the DTC between -Switzerland and Argentina
-The distributive rules and the elimination of double taxation
-Hierarchy and relation between treaty law and domestic law with particular attention to “treaty override” clauses
-Concurrent allocation of taxing rights
13h - End of the lecture
Monday, 19.07.2010
19h - Interpretation of Double Tax Conventions
Professor/Lecturer: Lic. iur. Roland A. Pfister, EMBA
General Overview
Domestic Rules of interpretation versus the recognized rules governing the interpretation of an international agreement
The relevance of the Vienna Convention
The relevance of the OECD Model and OECD Commentary
The relevance of the OECD Reports
The relevance of domestic tax legislation
The relevance of parallel treaties
The relevance of the foreign legislation
22h - End of the lecture
Thursday, 22.07.2010
19h - Cross-border Case Studies between Switzerland and Argentina
Professor/Lecturer: Lic. iur. Roland A. Pfister, EMBA, Eduardo O. Meloni, CPA, LLMIntroduction
Introduction to Swiss Tax Regimes - overview
-Lump Sum Tax Regime for individuals (with particular attention to the residence of individuals under DTCs)
-Holding Tax Regime
-Auxiliary Tax Regime (“Mixed Company”)
-Service Tax Regime
-Swiss Finance Branch
-Tax holidays and other state incentives
Outbound Case Studies between Switzerland and Argentina
22h - End of the lecture
Saturday, 24.07.2010
9h - Cross-border Case Studies between Switzerland and Argentina
Professor/Lecturer: Lic. iur. Roland A. Pfister, EMBA, Eduardo O. Meloni, CPA, LLM
Introduction
Inbound Case Studies between Switzerland and Argentina
Practical Case Study for students with short presentation of their results
13h - End of the lecture
Monday, 26.07.2010
19h - Interpretation of Double Tax Conventions to Collective Investment Schemes and Trusts
Professor/Lecturer: Lic. iur. Roland A. Pfister, EMBA
Introduction and presentation to my research on the “Application of Double Tax Convention to Trusts and Collective Investment Schemes”
Trust structure
-The Trust structure with comparison to the Argentinean “fideicomisio” structure
-The taxation of trusts in a purely domestic scenario CIS structure
-The taxation of CISs in a purely domestic scenario
-The taxation of carried interests
Recovery of withholding taxes on investments of CIS and trust structures
22h - End of the lecture
