2024-2025 / DROI1361-1

Corporate tax law

Part 1: Restructuring and reorganisation

Part 2: Relationships between connected companies (national and multinational groups)

Duration

Part 1: Restructuring and reorganisation : 15h Th
Part 2: Relationships between connected companies (national and multinational groups) : 15h Th

Number of credits

 Advanced Master in Tax Law4 crédits 

Lecturer

Part 1: Restructuring and reorganisation : Jean-Michel Degée
Part 2: Relationships between connected companies (national and multinational groups) : Aymeric Nollet

Language(s) of instruction

French language

Organisation and examination

Teaching in the second semester

Schedule

Schedule online

Units courses prerequisite and corequisite

Prerequisite or corequisite units are presented within each program

Learning unit contents

Part 1: Restructuring and reorganisation

The course objective is to teach the students the fiscal elements of company restructuring and reorganising, both for the companies that are subject of the changes and for their shareholders.
The first part of the course will be devoted to the fiscal aspects of the constitution of companies and to the subsequent changes in capital.
The second part broaches the fiscal regime of liquidation of companies, partial sharing and repurchase of own shares.
The students will then be introduced to mergers and divisions of companies in the Belgian and European contexts, contributions from universality and from branches of activity, exchange of shares.
Examples will be used in the course to familiarise the student with accounting issues of the different operations.

Part 2: Relationships between connected companies (national and multinational groups)

This part is devoted to relationships between associated companies and in particular will address the following fields:
- the problem of indirect transfer of profits between associated companies;

- the tax processing of financial flows within a group of companies: dividends, interest, royalties;

- the problem of recovering losses from subsidiaries and secure companies established abroad.
The problems are examined from the perspective of income tax.

Learning outcomes of the learning unit

Part 1: Restructuring and reorganisation

At the end of the course, the students should know the principles governing reorganising and restructuring companies and the fiscal rules involved in each operation.
They should be able to identify the essential issues to be examined during each operation of restructuring or reorganising and have a good mastery of their accounting issues.

Part 2: Relationships between connected companies (national and multinational groups)

The aim of this course is to provide students with the correct reflexes to analyse the taxation consequences and opportunities involved in organisational relationships between associated companies.

Prerequisite knowledge and skills

Part 1: Restructuring and reorganisation

Good knowledge of company taxation and good basis in accountancy law.

Part 2: Relationships between connected companies (national and multinational groups)

No translation.

Planned learning activities and teaching methods

Part 1: Restructuring and reorganisation

Lectures.
Discussion of cases and practical examples.

Part 2: Relationships between connected companies (national and multinational groups)

No translation.

Mode of delivery (face to face, distance learning, hybrid learning)

Part 1: Restructuring and reorganisation

Face-to-face. Broadcasts of classes are also available.

Part 2: Relationships between connected companies (national and multinational groups)

Face-to-face course


Additional information:

Face to face.

Course materials and recommended or required readings

Part 1: Restructuring and reorganisation

Course notes covering most of the course will be made available to the students.
The PowerPoint slides used during the lessons will also be made available to the students.
These media will be complemented with personal notes.

Part 2: Relationships between connected companies (national and multinational groups)

No translation.

Part 1: Restructuring and reorganisation

No translation.

Part 2: Relationships between connected companies (national and multinational groups)

Exam(s) in session

Any session

- In-person

written exam


Additional information:

Exam(s) in session

Any session

- In-person

written exam ( multiple-choice questionnaire, open-ended questions )


Additional information:

No translation.

Work placement(s)

Part 2: Relationships between connected companies (national and multinational groups)

No.

Organisational remarks and main changes to the course

Part 1: Restructuring and reorganisation

./.

Contacts

Part 1: Restructuring and reorganisation

jm.degee@arteo.law

Part 2: Relationships between connected companies (national and multinational groups)

Aymeric Nollet

Association of one or more MOOCs