16th Annual London Finance and Capital Markets Tax Conference
25 Jan - 26 Jan 2027
Session information
Substance under scrutiny: HoldCos, beneficial ownership and treaty access
Monday 25 January (1500 - 1600)
Description
As tax authorities continue to challenge cross-border structures, holding companies remain a key focus of audits, disputes and litigation. This panel will examine emerging developments in beneficial ownership, treaty access and substance requirements, as well as recent challenges involving participation exemptions, withholding tax relief and intermediary holding structures. Speakers will explore how courts and tax authorities are applying anti-abuse principles, GAAR and economic substance tests, and discuss practical strategies for managing risk in an increasingly contentious environment.
Session / Workshop Chair(s)
| Francesco Gucciardo | Aird & Berlis, Toronto, Ontario, Canada |
Speakers
| Sophie Donnithorne-Tait | Macfarlanes LLP, London, England |
| Michal Nowacki | Wardynski & Partners, Warsaw, Poland |
| Joshua Odintz | Holland & Knight, Washington, District of Columbia, USA |
| Raul-Angelo Papotti | Chiomenti Studio Legale, Milan, Italy |
| Elissa Romanin | MinterEllison, Melbourne, Victoria, Australia |