6th Annual IBA Tax Conference
30 Jan - 31 Jan 2017
Tuesday 31 January (1115 - 1230)
European Regional Forum
Taxation Section (Lead)
• 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?