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Thursday 2 December (0850 - 0900)

Thursday 2 December (0900 - 1030)

Programme details

Uncertainty is bad for business and investments. We are moving towards a new world order, as far as taxation of digital services and consumer-facing businesses are concerned. Concepts that were previously familiar and certain are now overlaid by new concepts.

The OECD’s Pillar 1 attempts to chart a unifying approach for countries to agree on a new basis for taxation of digital and consumer-facing activities. The UN is taking its own approach with Article 12B of the UN Model Double Taxation Convention, as well as working on its own initiatives. Where are we now and what is the impact on multi-jurisdictional businesses?

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Thursday 2 December (1030 - 1100)

Thursday 2 December (1100 - 1230)

Programme details

Unprecedented, uncertain, and life-changing: Covid-19 has upended life and business in unimaginable ways. It brought companies into financial distress and is resulting in insolvencies and restructurings.

What challenges and opportunities may it offer? Tax and fiscal policies have been among the tools used by governments around the world to save their economies, businesses, and livelihoods.

What is the impact of these tax policies?

What will happen when COVID-19 support is removed?

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Thursday 2 December (1230 - 1400)

 

Thursday 2 December (1400 - 1530)

Programme details

In the wake of the PPT of the MLI and the ECJ Danish cases, did the ’beneficial ownership’ concept get a new twist? How are anti-abuse rules applied worldwide? The anti-abuse rules and the CJEU’s rulings in the Danish beneficial owner cases are likely to have a significant impact not only on multinational group structures, but also on transactions among unrelated parties.

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Session/Workshop Chair(s)

Thursday 2 December (1530 - 1600)

Thursday 2 December (1600 - 1730)

Programme details

Model rules that give effect to the GloBE rules are due to be developed by the end of November 2021. So, we should have an early opportunity to consider some of the key issues including the rules’ design, operation and scope, as well as the effective tax rate calculation. We will consider the carve outs and exclusions and how GloBE and GILTI may co-exist.

We will also consider practical issues, such as how an agreement at OECD will impact US tax reform and whether the GloBE proposal is the only way forward now. Finally, do taxpayers and tax authorities have certainty at last? What are the practical considerations of working within this new environment?

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Session/Workshop Chair(s)

Thursday 2 December (1730 - 1745)

Thursday 2 December (1745 - 1900)

Friday 3 December (0900 - 1030)

Programme details

Decisions are made under the pressure of social scrutiny and there are demands for greater public supervision by NGOs, ESG and the world at large. This panel will analyse the challenges that corporate taxpayers face in keeping a balance between corporate citizenship and financial optimisation.

Topics include:

  • Is taking advantage of incentives for investments, such as green or social policy tax incentives, viable given public scrutiny?;
  • Are there changes in structuring and tax planning as a result of the rules on tax transparency, disclosure and the impact of NGOs and ESG?;
  • Are HNWI and UHNWI taking into consideration social scrutiny and citizenship in their tax planning?;
  • Has their attitude changed towards tax planning when it may affect their social reputation?; and
  • Are the courts being influenced by public opinion?

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Friday 3 December (1030 - 1100)

Friday 3 December (1100 - 1230)

Programme details

This session will provide practical insights from industry practitioners on multilateral tax audits, investigations, arbitrations and mutual agreement procedures (MAPs) in the age of increasing scrutiny from global tax authorities against both taxpayers and other tax authorities.

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Session/Workshop Chair(s)

Friday 3 December (1230 - 1245)

Friday 3 December (1245 - 1345)