6th Annual IBA Tax Conference

30 Jan - 31 Jan 2017


Session information

Brexit – EU tax consequences for financial institutions and others


European Regional Forum (Lead)
Taxation Section (Lead)


• 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)

Session / Workshop Chair(s)

Steve Martin Edge Slaughter and May, London, England


Sandy Bhogal Gibson, Dunn & Crutcher, London, England
Nikolaj Bjørnholm Bjørnholm Law, Hellerup, Denmark
Walter H Boss LL.M. Bratschi Ltd, Zürich, Switzerland
Peter Vincent Maher
Clemens Schindler Schindler Rechtsanwälte GmbH, Vienna, Austria
Klaus Sieker Flick Gocke Schaumburg Partnerschaft mbB, Frankfurt, Germany
Rom Watson Ropes & Gray LLP, Boston, Massachusetts, USA