This all-day seminar was devoted to the case studies on Corporate Income Tax. We have covered the following agenda:

• Definition of income for income tax purposes
• Financial investments
• Various - tax deductible costs, tax base determination
• Exit tax and M&A transactions
• Transparent entities
• Practical application of Double Tax Treaties

The Google search of “Cyprus company“ gives the outcome such as “Cyprus: Tax Heaven”, “tax benefits of Cyprus”, etc. Cyprus but also other traditional holding jurisdictions like the Netherlands or Luxemburg are deemed to be tax heavens and are automatically connected with the aggressive tax planning or the tax avoidance. 

However, on certain conditions holding companies in these jurisdictions are fully legitimate. We covered this topic on the Conference on international taxes organised by the Slovak Chamber of Tax Advisors in cooperation with AmCham Slovakia and IFA.

Issues covered:
- Tax residence of the company as defined in the Slovak Income Tax Act
- Definition of the place of effective management under the Slovak ITA
- Definition of the beneficial owner in Slovak law
- Interpretation of these terms under the Double Tax Treaties
- Case law of the Court of Justice of the EU
- Case studies
Panelists: Jozef Danis, SKDP, Renáta Blahova, IFA

On the Conference on "Taxation of various items of income derived by individuals from securities and shares in companies" we covered the following areas:

• Introduction to the taxation of income from securities - legal basis
• Dividends and shares on profit
• Interest income
• Income from the sale of securities and shares in companies
• Tax deductible costs
• Preparation of the income tax return - practical tips
• Income flowing to husband and wife - joint ownership
• In-kind contributions of securities and shares to the share capital and other reserves
• Distributions from the share capital and other reserves
• Income from other counties and Double Tax Treaties application

We appreciated the levely discussion of all participant - tax advisors, investors and traders.

Starting from January 2018, important tax changes in M&A transactions become effective. The domestic, Slovak M&A transactions will have to be performed at fair value for income tax purposes. As a result, they will require thorough tax planning. In addition to this, the concept of exit tax will be introduced.

We covered these topics in detail on the Conference on International Taxation "Does the tax optimisation still exist?/ Most significant changes in international taxes in the last 60 years" that was organised by the Slovak Chamber of Tax Advisors.