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Sunday 29 January (0000 - 0000)

European Regional Forum (Lead)
Taxation Section (Lead)

Session/Workshop Chair(s)

Monday 30 January (0830 - 1100)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Tax impact of EU law • Taxation of interest, dividends, hybrids, royalties • VAT and customs duties • Corporate tax • Withholding tax for payments from continued application of EU tax law (regulations, directives, ECJ decisions) until exit • Impact of BEPS on UK, EU and US • Will EU parent – subsidiary directive, EU margins directive, EU avoidance tax directive and EU single market financial services directive apply? • Protection against discriminatory EU tax • Impact on EU subsidiaries of UK companies • Cooperation between UK and EU with respect to information and collection of taxes • Need for tax treaties with some EU countries • Possible restructuring of UK companies (branch vs subsidiaries in EU), Irish inversion • No exposure to state aid if not in EU • Social security contribution for UK employees working in EU • Possible trade alternatives (Norway, Switzerland, Turkey, Canada WTO rules) • Issues on moving headquarters from UK – where to go (Ireland)

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Session/Workshop Chair(s)

Monday 30 January (1115 - 1245)

M&A

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Recent trends in LBO transactions (eg, Italian guidance) • Financing strategies (including for Africa) • Mergers • New IRS regulations • US inversions • Recent M&A transactions • Planning for IP • Impact of treaty shopping • Post-merger tax planning – Simplify structure – Financing – Debt push down – Loss utilisation – Paid up capital for Canada – Tax rulings in different structures

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Session/Workshop Chair(s)

Monday 30 January (1315 - 1430)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• 385 regulations in the US – related party debt turned into nondeductibility equity • 956 risk of guarantees – dividend risk • Characterisation of inter-company obligations for multinationals • US withholding tax on deemed dividends under 305(c) (convertible debt) and 871(m) dividend equivalent payments • Which BEPS action plans will be adopted in the US

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Monday 30 January (1445 - 1615)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• BEPS interest relief restrictions • UK draft legislation • OECD September Proposal • Imputed interest • Recharacterisation • Corporate treasury functions under CBC reporting • Direct lending vs bonds • Brisal-Auto Estadaas du Litiral SA Care (13 July 2016) • Implementation of Italian NPLs State Guarantee Scheme

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Monday 30 January (1615 - 1700)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Setting up or expanding financial services business in London or migrating business to the EU • Swiss corporate tax harmonisation III • Cross-border dividend trades • Interest structure • Hybrids and other financial investments • Basel capital requirements – AT1, AT2 and TLAC securities, including BEPS considerations off balance sheet financing • Cross-border dividend trades, including US section 871(m) and 305(c) rules

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Session/Workshop Chair(s)

Monday 30 January (1700 - 1815)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Use of derivatives • Common asset classes and structures • Effect on character, source, timing and amount • Relationship with treaty and domestic issues • Current issues • The effect of the use of derivatives

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Session/Workshop Chair(s)

Monday 30 January (1830 - 1930)

European Regional Forum (Lead)
Taxation Section (Lead)

Monday 30 January (1930 - 2200)

General Interest

Tuesday 31 January (0900 - 1100)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Automatic exchange of information • Introduction of GAAR and EU Anti-Tax Avoidance Directives (eg, Italy) – a comparison • Holding companies under attack • Proposed regulations dealing with US limited liability companies wholly owned by a foreign person • Controversy and impact of BEPS • Comparison of OECD BEPS reports and EU measures • Review and update on state aid cases • Panama Papers

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Session/Workshop Chair(s)

Tuesday 31 January (1115 - 1230)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• BEPS and transfer pricing units • Arm’s length principal revisited • Guidance on profit splits • Documentation requirements for financial interest rates and financial contribution • Risk/recharacterisation/capital arrangement • State aid • Establishment of appropriate fees for guarantees and keep well • Chevron case • Experience with mutual agreement procedures regarding adjustment of interest rates and financial conditions • Collective investment vehicles – do they meet European tax exemptions?

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Tuesday 31 January (1330 - 1430)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Impact of treaty shopping on structuring funds • Impact of other BEPS action plans • Structuring funds • Carried interest • Structuring investments by funds • Structuring financing • Impact of new audit procedures in US for partnerships • Impact on foreign investors in US partnerships • Impact of new rules for US foreign partnerships (including hybrid entities)

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Session/Workshop Chair(s)

Tuesday 31 January (1430 - 1545)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Corporate treasury functions under CBC reporting • Intra Group financing (cash pooling, Fx) • Characterisation of inter-company obligations • Common consolidated corporate tax base (EU Proposal) • Reputational risk

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Session/Workshop Chair(s)

Tuesday 31 January (1600 - 1730)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• New era inaugurated by BEPS and other OECD efforts triggered a serial of actions in non EU major emerging country jurisdictions • How relevant those developments are and how they impact the cross border relations and financial flows among investors in non EU jurisdictions and EU jurisdictions will be discussed in the panel • Panel discussions will include adoptions of measures related to transparency, GAAR, LOB, among others

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Session/Workshop Chair(s)

Tuesday 31 January (1730 - 1830)

European Regional Forum (Lead)
Taxation Section (Lead)

Programme details

• Functional currency elections • Timing of recognition • Impact of reorganisations and unwinding financing arrangements • Hedging – tax treatment • Impact on cash pooling

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Session/Workshop Chair(s)