IBA Annual Conference Miami 2022

30 Oct - 4 Nov 2022

Room 229 A, Level 2

Session information

Lights out for holding companies? The flight from havens and the evolution of source tax – whither withholding tax, intangibles and royalties?

Tuesday 1 November (1115 - 1230)

Room 229 A, Level 2
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Taxes Committee (Lead)


There is pressure to limit the existence and recognition of holding companies only to the extent that underlying substance and function is housed within the relevant jurisdiction. International tax law developments of the recent past and of the foreseeable future provide broad legal rules based on the OECD/G20 and the EU’s efforts to crack down on companies with slim infrastructure in low-tax jurisdictions or in countries with tax benefits for pure holding companies (especially IP-holding companies). This must be seen together with withholding taxes, non-deductibility rules for payments made to companies in low-tax jurisdictions, and the principal purpose test as well as limitation on benefits clauses. This panel will provide an overview of how international groups are responding to these developments.

Session / Workshop Chair(s)

Wiebe Dijkstra De Brauw Blackstone Westbroek, Amsterdam, Netherlands
Thais De Barros Meira BMA Advogados, São Paulo, Brazil


Yushi Hegawa Nagashima Ohno & Tsunematsu, Tokyo, Japan
Victor Hollender Skadden Arps, New York, New York, USA
Floran Ponce Lenz & Staehelin, Geneva, Switzerland