6th Annual IBA Tax Conference
30 Jan - 31 Jan 2017
etc.Venues
Session information
Committee(s)
European Regional Forum
(Lead)
Taxation Section
(Lead)
Description
• 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?
Speakers
Henry Birnkrant | Alston & Bird LLP, Washington, District of Columbia, USA |
Pascal Hinny | Lenz & Staehelin, Zürich, Switzerland |