Day 1 of the 10th IBA London Finance and Capital Markets Virtual Tax Conference

OECD/US update 1

This panel will explore:

• The current status of Pillar 1 and Pillar 2 of the OECD, with the guidance of Grace-Perez-Navarro, and with the input from the views of the US, Germany and Italy.
• Specific international changes of note for their jurisdiction, such as (finally) the implementation of ATAD in Germany; the possible changes of the US international rules under a Biden administration; the creditability of digital taxes in the US.
• The OECD Guidance on Intercompany Financial Transactions of February 2020 and its implications on transfer pricing.

Moderators

• Mariana Díaz-Moro Paraja, Gomez-Acebo & Pombo, Madrid
• Sylvia Dikmans, Houthoff, Amsterdam
• Shane Milam, Paul Weiss, New York
• Clemens Schindler, Schindler Attorneys, Vienna
• Michael Schmidt, Schmidt Tax Law, Frankfurt
• Eric Sloan, Gibson Dunn, New York / Washington, DC

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EU/UK update 2

UK and EU tax developments – this panel will focus on key developments in the region and their likely impact on business. As the EU Commission and OECD both look to increase their impact and individual jurisdictions look for opportunities to stem avoidance or extend their reach, the panel will focus on 4 particular areas:

• State Aid in the tax arena – where is the line between genuine tax competition and disguised State Aid likely to fall after the current round of litigation?
• Pillar 2 – a sensible anti-avoidance measure designed to discourage the aggressive use of low tax areas or an attempt by the big countries to reduce the impact of legitimate tax competition by those less economically fortunate?
• Extension of the scope of PE taxation and implementation of anti-hybrid rules – are countries legitimately reacting to new ways of doing business or is this all going too far in taxing extra-territorially? Is the principle behind the imported mismatch rules correct and how much are countries doing to enforce that principle?
• Withholding taxes – what role do they, and should they, play in terms of extra-territorial taxation? The debate going on in The Netherlands draws the issues out well.

Moderators

• Mariana Díaz-Moro Paraja, Gomez-Acebo & Pombo, Madrid
• Sylvia Dikmans, Houthoff, Amsterdam
• Shane Milam, Paul Weiss, New York
• Clemens Schindler, Schindler Attorneys, Vienna
• Michael Schmidt, Schmidt Tax Law, Frankfurt
• Eric Sloan, Gibson Dunn, New York / Washington, DC