Questions on your Remuneration ?

1. Questions on yourRemuneration? A few possible tax treatments of your remuneration as an individual

2. 1. Taxation of Employees and Directors Taxation of Employees : Taxationin the Home State 1st Exception: Taxation of Professional Income in the Work State Exception of the Exception : Taxation in the Home State : « The 183 Days Rules » Cases Taxation of Directors 2. Salary Split of Employees and Directors

3. Principle: Taxation In The Home State Taxation of Employees Some countries have an interestingLowerTax/SS Rate Example: Cyprus, Serbia, Bulgaria, Malta, …

4. Salary Taxes, Social Security And Expatriate Taxation In 2011

5. TaxFreedom Day

6. Taxation of Employees 1st Exception: Taxation Of Professional Income In The Work State Article 15 of the OECD Model Tax Convention provides for taxation of IncomefromEmployment

7. Taxation of Employees c) Exceptionof the Exception : Taxation in the Home State : « The 183 Days Rules » the recipientispresent in the other State for a period or periods not exceeding in the aggregate 183 days in the calendaryearconcerned, and; 2. the remunerationispaid by, or on behalf of, an employer whois not a resident of the other State, and; 3. the remunerationis not borne by a permanent establishment or a fixed base which the employment has in the other State.

8. d) Cases Taxation of Employees Miss X, 22 yearsold, Irish resident, works in Belgium for an Irish Resident Employer and stays for 200 days in Belgium Taxation in Belgium Miss X, 22 years old, Irish resident, works in Belgium for an Irish Resident Employer who has no permanent establishmentin Belgium and staysfor 160 days in Belgium  Taxation in Ireland

9. Taxation of Directors (1)Director'sfees and similarpaymentsderived by a resident of a Contracting State in hiscapacity as a member of the board of directors on a similarorgan of a companywhichis a resident of the otherContracting State maybetaxed in thatother State. (2)The remunerationwhich a person to whomparagraph (1) appliesderivesfrom the company in respect at the discharge of day-to-dayfunctions of a managerial or technical nature maybetaxed in accordance with the previsions of Article 15.

10. 2. The Salary Split Technique essentiallyimplemented for taxreasonsconsistingto split the payment of incomes between different countries to benefit from tax exempt portions, reduce the mechanisms of progressive taxation and to benefit from lower tax rates between several countries. Benefit from the tax exemption portion Use double tax treaties

11. Questions? Thankyou for your attention!