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PRODID:-//Session events Calendar//IBA//EN
CALSCALE:GREGORIAN
VERSION:2.0
BEGIN:VEVENT
DTSTAMP:20260504T165311Z
DTSTART:20171012T093000Z
DTEND:20171012T123000Z
SUMMARY:Multilateral instrument: speed dating tax style - how are you imp
 acted?
DESCRIPTION:On 7 June 2017\, 68 countries signed the multilateral treaty 
 to implement\, among others\, the treaty abuse rules (principal purpose 
 test or limitation on benefit provision) and binding arbitration provisi
 ons in the framework of the \\organisation for Economic Co-operation and
  Development Base Erosion Profit Sharing Action Plan. The agreement requ
 ired certain minimum standards be implemented but provided different app
 roaches. Countries could opt out of parts of the agreement with reservat
 ions. Hence\, most\, but not necessarily all\, signatories may also have
  included provisions for transparent entities\, restrictions on dividend
  transfers\, expanded ability to tax share sales of real estate companie
 s or new permanent establishment rules.\n\nThe multilateral treaty allow
 s participating countries to effectively amend their treaties without ye
 ars of negotiation. The US\, Brazil and Saudi Arabia didn't sign the agr
 eement.\n\nThis landmark agreement will have a significant impact on exi
 sting structures and the future of international tax planning. This pane
 l will review the impact of the agreement on holding companies\, financi
 ng structures\, IP structures commissionaire arrangements and supply cha
 in structures. The likely interpretation of the principal purpose  test 
 will be considered. The impact of the US not signing will be discussed.
LOCATION:Room C4.4\, Convention Centre\, Level 4
UID:7740cea1-a89e-419a-9d27-5892c3a69a75
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