Day 6 of the 10th IBA London Finance and Capital Markets Virtual Tax Conference
Day 6 of the the IBA 10th IBA London Finance and Capital Markets Virtual Tax Conference
17 FEB 2021 1400 – 1600 GMT / 0900 – 1100 EST
Global trends in tax controversy
This panel will bring perspectives from North and South America, Asia, and Europe, to a discussion of global trends in tax controversy. Potential topics for this panel include:
- Mutual agreement (MAP) and competent authority developments
- The impact of BEPS on enforcement and controversy
- Recent important decided cases that have multinational ramifications
- Information exchange issues, including CbyC, CRS, and FATCA, and their impact on enforcement and controversy
- The impact of the pandemic and recent political developments on tax enforcement and controversies
Phil West
Steptoe & Johnson, Washington, DC
David Liu
Duan & Duan, Shanghai
Raquel Novais
Machado Meyer, Sao Paulo
Dirk Pohl
McDermott Will & Emery, Munich
Moderators
- Walter H Boss, Bratschi, Zurich
- Aseem Chawla, ASC Legal, Delhi
- Reinout de Boer, Stibbe, Amsterdam
- Sam K Kaywood, Alston & Bird, Atlanta, Georgia
- Carolina Rozo, Philippi Prietocarrizosa Ferrero DU & Uria, Bogota
- David G Shapiro, Saul Ewing Arnstein & Lehr, Philadelphia, Pennsylvania
- Benjamin Twardosz, Cerha Hempel, Vienna
EU anti-abuse rules and beneficial ownership
Topics will include:
- The overlap of anti-abuse rules in investment structures: domestic GAARs, Parent Subsidiary Directive on dividends and on interest and royalties, ATAD and Tax Treaties.
- The impact of ECJ Danish cases in the interpretation of the Parent Subsidiary Directives.
- Is beneficial ownership an independent anti-abuse rule in addition to substance requirements and business purpose.
- Recent legislative, regulatory and judicial developments on beneficial ownership after ECJ Danish cases.
- Interpretation of the beneficial ownership concept.
- Beneficial ownership and Tax Treaties. Is beneficial ownership and implicit rule? Beneficial ownership beyond articles 10 to 12 MCOECD.
- Recent challenges on application of Tax Treaties and Parent Subsidiary Directive in private equity structures.
Albert Collado
J&A Garrigues, Madrid
Luana Foffo Ciucci
Procter & Gamble, Rome
Thierry Lesage
Arendt & Medernach, Luxembourg City
Jakob Schilder-Knudsen
Lundgrens, Hellerup
Pieternel Verhoeven - van den Brink
Nauta Dutilh, Amsterdam
Moderators
- Walter H Boss, Bratschi, Zurich
- Aseem Chawla, ASC Legal, Delhi
- Reinout de Boer, Stibbe, Amsterdam
- Sam K Kaywood, Alston & Bird, Atlanta, Georgia
- Carolina Rozo, Philippi Prietocarrizosa Ferrero DU & Uria, Bogota
- David G Shapiro, Saul Ewing Arnstein & Lehr, Philadelphia, Pennsylvania
- Benjamin Twardosz, Cerha Hempel, Vienna
Certificate of Attendance
Certificates of attendance for each session will be provided, automatically, to all delegates who have registered in advance and attended the live broadcast for a minimum of 30 minutes based on verified sign-in and sign-out times. Certificates can only be issued to the name provided at the time of registration. If you have any queries relating to your Certificate of Attendance, please email webinars@int-bar.org.