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Monday 17 January (1300 - 1400)

Programme details

This panel will discuss big global tax issues, such as:

  • What the future holds for the next five years;
  • OECD/G20 Global Pillars 1 and 2;
    • Pillar 1: what are the issues still and what is the most likely
      outcome? How has the change of direction left those keen to
      tax, or reconcile the taxation of, digital operators?;
    • Pillar 2: what is the likely outcome? Where does this leave bona fide tax competition for least developed countries (LDCs) and others?; and
  • The balance of power in terms of initiatives for confirming global tax rules and dealing with perceived abuses.

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Session/Workshop Chair(s)

Monday 17 January (1400 - 1520)

Programme details

  • Background of the proposal and implementation timeline;
  • Overview of rules and ordering;
  • What tax base is used?;
  • Substance-based carve-outs;
  • Country participation vs non-participation;
  • The challenges of treaty implementation;
  • The application of Pillar 2 to investment funds;
  • The US controlled foreign company (CFC)/global intangible low taxed income (GILTI) rules and their relation to Pillar 2; and
  • The end of tax competition? What is left?

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Session/Workshop Chair(s)

Monday 17 January (1520 - 1610)

Programme details

  • The approach to OECD/G20 Global Pillars 1 and 2;
  • The approach to promoting inbound investments;
  • Trends in tax treaties, negotiations and revisions;
  • Trends in enforcements; and
  • A look to the future: the tax horizon.

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Session/Workshop Chair(s)

Monday 17 January (1610 - 1640)

Tuesday 18 January (1300 - 1410)

Programme details

  • Tax governance and ESG – tax policies;
  • Audit trends and the impact on country-by-country reporting;
  • Transfer pricing; and
  • The Directive on Administrative Cooperation 6 (DAC 6) and transparency.

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Session/Workshop Chair(s)

Tuesday 18 January (1410 - 1510)

Programme details

  • Updates on the unilateral digital service tax (DST) – feedback from Italy, France (DST), Mexico (no DST) and the Netherlands;
  • The main digital business aspects of the OECD/G20 Global Pillars 1 and 2, interaction with current US tax reform and the EU approach;
  • The Directive on Administrative Cooperation 7 (DAC 7) reporting for digital platform and joint audits;
  • Updates on the litigation of digital cases and the current attitude of the tax authorities with digital businesses; and
  • Other tax developments affecting cross border digital activities.

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Session/Workshop Chair(s)

Tuesday 18 January (1510 - 1610)

Programme details

  • The evolution of the classification of crypto assets;
  • The intersection of traditional and new capital markets;
  • Financing blockchain projects – token offerings and other financing vehicles;
  • New twists on traditional instruments/activities – Lending/ Decentralised Finance (DeFi), staking, and stablecoins;
  • Tax compliance and enforcement in a decentralised environment;
  • Application of tax concepts to Decentralised Autonomous Organisations (DAOs) and DeFi;
  • Location, sourcing and withholding issues
  • Information reporting and the exchange of information.

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Session/Workshop Chair(s)

Tuesday 1 March (1300 - 1435)

Programme details

This panel will focus on the latest developments in de-SPAC transactions, including the unique challenges and opportunities that arise in cross-border transactions.

The panel will explore:

  • Recent de-SPAC trends;
  • Going public with a special purpose acquisition company (SPAC) vs an initial public offering (IPO);
  • Notable tax considerations in different jurisdictions;
  • Re-domiciling the SPAC;
  • Founder shares and sponsor considerations;
  • 'Double dummy’ transactions;
  • Triangular amalgamations; and
  • Other combination structures.

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Session/Workshop Chair(s)

Tuesday 1 March (1435 - 1610)

Programme details

  • The use of holding companies in M&A;
  • Private equity and substance – physical concepts in a virtual world;
  • Regulated entities
  • M&A management compensation
  • DAC 6 hybrid issues

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Session/Workshop Chair(s)

Tuesday 1 March (1610 - 1640)

Wednesday 2 March (1300 - 1430)

Programme details

  • An overview of US tax reform proposals and their current status’, including issues of interest to non-US investors;
  • US offshore lending developments;
  • Proposals affecting the deductibility of interest, including 163(n) IRC on excess debt;
  • Recent changes to Passive Foreign Investment Company (PFIC) regulations of interest to non-US corporations; and
  • Updates on GILTI and developments affecting worldwide minimum taxes.

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Session/Workshop Chair(s)

Wednesday 2 March (1430 - 1610)

Programme details

  • Trends in taxation of cross border interest;
  • Domestic developments on withholding tax on cross border interest in countries such as the Netherlands;
  • Financing domestic acquisitions from abroad: debt-equity distinctions and the future of hybrid financing after BEPS Action 2 and the EU anti-tax avoidance Directive 2;
  • Interest barrier rules;
  • Notional interest deductions (NIDs) and special regimes;
  • The Debt-Equity Bias Reduction (DEBRA) allowance that has been launched by EU;
  • Changes in financial structures as a result of OECD/G20 Global Pillars 1 and 2;
  • The Directive on Administrative Cooperation 6 (DAC 6) and financial transactions; and
  • Intragroup financing and treasury companies – challenges between new CFC rules and OECD transfer pricing guidelines on financial transactions and beneficial ownership requirement.

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Session/Workshop Chair(s)

Wednesday 2 March (1610 - 1640)

Thursday 3 March (1300 - 1415)

Programme details

This panel will examine the latest cases that impact on crossborder finance and capital markets including on treaty abuse, other anti-avoidance measures, recent case law on financing transactions, managing international tax disputes and transparency issues.

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Session/Workshop Chair(s)

Thursday 3 March (1415 - 1530)

Programme details

  • The key points and trends in transfer pricing litigation, including Italian Supreme Court case no 1232 (January 21 2021), Coca-Cola v IRS (November 18 2020), among others;
  • New developments in applying transfer pricing rules to financial transactions;
  • How tax authorities’ transfer pricing audits are evolving for hidden permanent establishments, forward subscription structures and other cases;
  • The changing role of profit split methods in resolving transfer pricing disputes;
  • Update on the mutual agreement procedure (MAP) and advance pricing agreement (APA) procedures; and
  • Practical issues and the impact of Covid-19 on transfer pricing and year-end adjustments.

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Session/Workshop Chair(s)

Thursday 3 March (1530 - 1610)

Programme details

  • Structuring income from IP (synthetic royalties);
  • IP planning after the OECD/G20 Global Pillar 2;
  • IP planning in the context of CFCs;
  • IP migration and/or onshoring of IP;
  • Withholding tax problems for royalties based on where a patent is registered;
  • The problems with sourcing software related income for IP maintained in the cloud;
  • The potential impacts of pending US tax legislation; and
  • Substance requirements

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Session/Workshop Chair(s)

Thursday 3 March (1610 - 1640)

Friday 4 March (1300 - 1420)

Programme details

  • The UK tax arena post-Brexit;
  • Withholding tax developments;
  • The impact on tax treaties and EU directives, such as the new German anti-treaty shopping rules and new Italian dividend which withholds a tax exemption for distributions to EU regulated funds;
  • The EU anti-tax avoidance Directive 3 (ATAD 3)/EU shell entities initiative;
  • The EU anti-tax avoidance Directive 2 (ATAD 2);
  • OECD/G20 Global Pillar 2; and
  • Country-by-country financial reporting.

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Session/Workshop Chair(s)

Friday 4 March (1420 - 1510)

Programme details

  • Charting the upheaval from the Denmark cases;
  • Shell entities and economic substance under the EU Anti-Tax Avoidance Directive 3 (ATAD 3): challenges with a one size fits all policy;
  • Navigating OECD/G20 Global Pillar 2; and
  • The appropriate strategies for change: removing problematic holding companies or bolstering local substance.

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Session/Workshop Chair(s)

Friday 4 March (1510 - 1610)

 

Programme details

  • The current tax issues for investment managers;
  • The latest developments in fund structuring;
  • Exiting private equity fund investments in Spain and Italy; and
  • New trends in investment strategies and their unique tax issues.

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Session/Workshop Chair(s)