Description

The growth of a company generally occurs through the creation of subsidiaries for multiple reasons: integrating new investors, ensuring a division of risks, developing the activity internationally... This development in the form of a group leads to questions about taxation. The objective of this training is to provide an overview of the most common tax issues associated with the creation and management of a group of companies.

Who is this training for ?

For whom ?

Accounting and financial manager wishing to have an overview of tax issues relating to the formation of a group.

Prerequisites

None.

Training objectives

Identify the tax issues linked to the existence of a group.

Control the tax risks associated with the group's internal operations.

Manage the group's current taxation in terms of IS and VAT.

Identify the advantages and constraints of the tax integration regime.

Training program

• Identify the implications of the existence of the group on taxation
  • Intragroup transactions: the abnormal act of management; the principle of transactions at a normal price and the permitted exemptions.
  • The question of taxation of group companies: subject companies to the IS; companies not subject to the IS.
• Situate the tax constraints relating to intra-group financing transactions
  • Devices to limit deductible interest.
  • Undercapitalization.
  • Debt waivers: deductible and non-deductible aid; aid with regard to VAT.
• Delimiting the risks linked to transfer pricing The issue of transfer pricing.
  • Setting transfer prices within the group.
  • The documentation to be compiled.
  • Prior agreement procedures.
  • The methods of control of the administration.
• Master the tax regime for participations and dividends Tax definition of participation securities.
  • Acquisition costs, depreciation and transfer of equity securities.
  • Taxation of dividends.
  • The regimes of parent and daughter companies.
• Form an integrated tax group
  • Conditions of access to the scheme.
  • Advantages and disadvantages.
  • The integration agreement.
• Identify the impact of the existence of the group on other taxes
  • Calculating the CVAE: calculating the effective tax rate.
  • Overview of VAT management in holding companies.
  • VAT liability .
  • Calculation of the deduction coefficient.
  • Consolidation of VAT payment.