Duration
Part 1: Restructuring and reorganisation : 15h Th
Part 2: Relationships between connected companies : 15h Th
Number of credits
| Specialised master in tax law | 4 crédits |
Lecturer
Part 1: Restructuring and reorganisation : Jean-Michel Degée
Part 2: Relationships between connected companies : Jean Thilmany
Language(s) of instruction
French language
Organisation and examination
Teaching in the second semester
Schedule
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
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
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
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
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
Face to face.
Organisational adjustments related to the current health context
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
No translation.
Assessment methods and criteria
Below you will find information on the evaluation methods planned for in-person and remote exams as well as those planned for hybrid sessions. Depending on how the health crisis evolves, the chosen method will be communicated to you no later than one month before the start of the exam session.
Part 1: Restructuring and reorganisation
No translation.
Part 2: Relationships between connected companies
Any session :
- In-person
written exam ( multiple-choice questionnaire, open-ended questions )
- Remote
written exam ( multiple-choice questionnaire, open-ended questions )
- If evaluation in "hybrid"
preferred remote
Additional information:
No translation.
Work placement(s)
Part 2: Relationships between connected companies
No.
Organizational remarks
Part 1: Restructuring and reorganisation
./.
Part 2: Relationships between connected companies
No translation.
Contacts
Part 1: Restructuring and reorganisation
jm.degee@arteo.law
Part 2: Relationships between connected companies
Email: j.thilmany@uliege.be