Cross-Border Effects of Restructuring Including Change of Legal Form

The Seminar will examine the tax effects in a particular jurisdiction of reorganisations taking place in another jurisdiction. The covered reorganisations include mergers, divisions or splits, but also change of legal form (e.g., partnership into a company) and transfer of the corporate seat. The Seminar will focus on the following: effects in the source State of reorganisations made in the residence State; effects in the residence State of reorganisations made in the source State; impact of EC tax directives on dividends and cross-border reorganisations; and treaty issues.