INTERNATIONAL FISCAL POLICY I Olivier BEDDELEEM

Introduction Taxation in a global environment

PART 1 : TAXATION OF PRIVATE PEOPLE 2 possibilities : –The countries did not sign a tax convention –The countries signed a tax convention

SEMINAR 1 : French Taxation of International Revenue

I- Taxation of French residents A- Definition of a French resident –1) Residence and nationality

–2) Criteria for residence –Alternative criteria Home Main residence Business activity Center of economic interests

B- Taxed revenues –1) Principle

–2) Exceptions : exemptions –Total exemption General rule Certain activities –Partial exemption

II- Taxation of non-residents

III- Double taxation

SEMINAR 2 : The OECD model tax treaty

I- The signature of a tax treaty A- What is a tax treaty ? B- Why sign a tax treaty ?

II- The OECD model tax treaty

III- The determination of the fiscal residence

IV- Taxable revenues A- Scope of the OECD treaty

B- Repartition of taxable revenues between the countries

Seminar 3 : Prevention of double taxation

Introduction : Why isn’t repartition enough ?

I- Exemption What is exemption ?

A- Total exemption

B- Partial exemption

C- Partial exemption in OECD treaties signed by France

II- Credit What is a credit ?

A- Total credit

B- Partial credit

C- Fictive credit