[ONLINE] Relief from Double Taxation – 12 November
This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:
- Economic double taxation (EDT) relief:
- Rationale & types of EDT relief;
- EDT relief mechanisms in the ITA;
- The full imputation system (article 31, 59 and 60 of the ITA);
- The participation exemption (as relevant for the relief of EDT); and
- The indirect foreign tax credit.
- Juridical double taxation relief:
- Rationale & types of JDT relief;
- Outbound considerations:
- Ordinary direct foreign tax credit system;
- Treaty relief
- Unilateral relief
- Commonwealth relief;
- Flat-rate foreign tax credit.
- The participation exemption (as relevant for the relief of JDT).
- Inbound considerations:
- Source rules;
- Treaty relief as applicable to Malta as the ‘other Contracting State’.
- Miscellaneous issues:
- Switch-over clauses;
- Anti-hybrid rules;
- Subject-to-tax rules.
- Outbound considerations:
- Rationale & types of JDT relief;
Seminar Description
Seminar Description
This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:
- Economic double taxation (EDT) relief:
- Rationale & types of EDT relief;
- EDT relief mechanisms in the ITA;
- The full imputation system (article 31, 59 and 60 of the ITA);
- The participation exemption (as relevant for the relief of EDT); and
- The indirect foreign tax credit.
- Juridical double taxation relief:
- Rationale & types of JDT relief;
- Outbound considerations:
- Ordinary direct foreign tax credit system;
- Treaty relief
- Unilateral relief
- Commonwealth relief;
- Flat-rate foreign tax credit.
- The participation exemption (as relevant for the relief of JDT).
- Inbound considerations:
- Source rules;
- Treaty relief as applicable to Malta as the ‘other Contracting State’.
- Miscellaneous issues:
- Switch-over clauses;
- Anti-hybrid rules;
- Subject-to-tax rules.
- Outbound considerations:
- Rationale & types of JDT relief;
CPE
Qualifies for 3 CPE Core hours under the core competency area.
Seminar Fee
The seminar fee is Non Member €70.00, Members €60.00. The fee covers seminar participation and access to event resources.
A receipt will be issued to all participants.
Event Resources
Participants will receive the event resources by email.
Additional Information
For more information, kindly use the following communication mediums:
T: 21 58 53 74 M: 77 01 17 19 E: info@skillsmalta.com Webpage: www.skillsmalta.com