Global Taxes

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Monday 16 January (0830 - 0930)

Programme details

  • Employees or Directors working from home: PE or not PE?
  • Recent case law on PEs and evolving trends
  • BEPS Multilateral instrument and PEs: a changing landscape?
  • Focus on auxiliary and ancillary activities amounting to PE (eg.: warehouse and purchasing office

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Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 16 January (0930 - 1030)

Programme details

  • Discussion of any recently published Pillar 2 implementation framework guidance
    • Current status of Pillar 2 implementation in key jurisdictions around the world
  • Interplay of Pillar 2 and the US tax system in the absence of any US legislation, including the interaction with GILTI and the new Corporate AMT
    • Status of domestic minimum top-up taxes and the interplay with CFC regime taxes and any GloBE safe harbors
  • The impact of Pillar 2 on domestic tax incentives and how those will change

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Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 16 January (1045 - 1050)

Monday 16 January (1050 - 1145)

Programme details

  • European dividends to non-EU funds
  • Anti hybrid and pre-existing avoidance rules
  • EU DEBRA proposed directive & interaction with anti-hybrid rules
  • Recent changes to the UK’s anti-hybrid rules

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Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 16 January (1145 - 1230)

Programme details

The panel will discuss selected hot topics in each jurisdiction:

  • Recognition of NPL losses in securitisation vehicles
  • Special purpose vehicles connected to securitisation transactions
  • Beneficial ownership of derivatives in the light of the Danish cases
  • Derivatives and cryptocurrencies

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Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 16 January (1330 - 1500)

Programme details

  • Multijurisdictional co-borrower structures
  • Debt push-downs and debt location
    • Principal purpose developments
  • Exemptions from withholding tax on interest
    • Beneficial ownership, principal purpose
  • Distressed debt considerations for distressed acquisitions
    • Interest barrier rules and impact on acquiring non-performing investments
    • Impact of inflation and currency fluctuation on interest barrier regimes

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Session/Workshop Chair(s)

Monday 16 January (1500 - 1630)

Programme details

  • ESG
  • Impact of tax transparency on multinationals
  • Handing an international tax audit

Please note this session will be held under Chatham House Rules

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Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 16 January (1630 - 1800)

Programme details

  • Unshell directive proposal
  • Pillar 2 in the EU
  • DEBRA and BEFIT (Business in Europe: Framework for Income Taxation)
  • Withholding tax recoveries
  • Practical experiences DAC 6
  • Tax enablers consultation (SAFE)

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Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 16 January (1830 - 2230)

Tuesday 17 January (0830 - 1000)

Programme details

  • Impact of Pillar 2 and EU directives
  • Fresh look at substance including ATAD3, DEMPE, new domestic rules (e.g.Canadian GAAR, harmonizing substance)
  • What if conflict between analysis of substance in Luxembourg conflicts with substance requirements in payor country?
  • Beneficial ownership
  • Impact on financings
  • Impact on funds
  • What if ATAD3 does not pass?

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Taxation Section (Lead)

Session/Workshop Chair(s)

Tuesday 17 January (1000 - 1115)

Programme details

  • Cross-Border Demergers/Split-Ups/Spin-Offs
  • Migrations and tax or corporate conversions
  • Cross Border LBOs in an anti leverage environment

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Taxation Section (Lead)

Session/Workshop Chair(s)

Tuesday 17 January (1130 - 1230)

Programme details

  • Tax issues in target jurisdictions (including anti-hybrid rules)
  • Brief overview of holding companies
  • Tax challenges at fund level and choice of fund vehicle
  • Developments in carry structuring
  • Tax issues for managers (including creating PEs)
  • LP tax requests

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Taxation Section (Lead)

Session/Workshop Chair(s)

Tuesday 17 January (1330 - 1430)

Programme details

  • APA practice trends and experience – increased demand for certainty
  • COVID & extraordinary events: Practical applications of methods to reflect impact of COVID, sanctions, etc.
  • Tax rulings issued by 2 or more countries in a single procedure (ICAP of OECD and ETAX of EU)
  • Transfer of functions across borders where employees move
  • Intercompany financing: dissecting the findings in HMRC v. Blackrock and Singtel (Federal Court of Australia) cases)
  • Data collection and sale by related companies

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Taxation Section (Lead)

Session/Workshop Chair(s)

Tuesday 17 January (1500 - 1630)

Programme details

  • Austria: cum/ex Supreme Administrative Court VwGH 28 June 2022 Ro 2022/13/0002
  • Canada: exchange of info Levett v CRA
  • Denmark: Beneficial ownership EU law C-116/16 T Danmark and C-117/16 Y Denmark ApS. (NetApp)
  • Italy: WHT regime on dividends paid to US investment funds EU law American funds insurance
  • Spain: deduction of borrowing costs Duscholux; recovery of excess withholding taxes by non-resident alternative investment funds EU law infringements (AIF´s or Hedge Funds).
  • UK: Cum/ex and Revenue rule SKAT v Solo Capital; Treaty abuse main purpose test Burlington v HMRC
  • US: exchange of info Puri v US

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Taxation Section (Lead)

Session/Workshop Chair(s)

Tuesday 17 January (1630 - 1730)

Programme details

  • What is Decentralised Finance (DeFi)?
  • How are lending transactions on marketplaces like AAVE taxed?
  • How is the provision of liquidity on DEXes like Uniswap taxed?
  • How is the provision of insurance coverage on Nexus Mutual taxed?
  • What are the tax consequences of DeFi rug pulls?

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Taxation Section (Lead)

Session/Workshop Chair(s)