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Christas Instructions - Task 4

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Christa’s instructions for step 1

FlyByU Group group structure


Christa Elsaesser
To You

Hi there,

You need to especially put your eye on the structure of the group, particularly on the fact
that FlyByU Group holds its Belgian subsidiaries via a US intermediary holding company.
Go to PwC’s Worldwide Tax Summaries and do a quick research on the withholding tax
rates on dividends between Belgium and the US, the US and Switzerland as well as
Belgium and Switzerland. Also look into the residual withholding tax rates on dividend
payments based on the respective double tax treaties (“DTT”), i.e. DTT between Belgium
and USA, DTT between Switzerland and the US and the DTT between Belgium and
Switzerland to make sure that the information provided on Worldwide Tax Summaries is
correct.

I hope this helps.

Best,
Christa

Virtual Case Experience Corporate Tax


PwC

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