The PwC Academy Fiscal Litigation

Transcription

1 Fiscal Litigation For many tax specialists, going to court is not an attractive prospect. The prospect of explaining a case to a tax judge can be daunting, at best. Nevertheless, litigation is becoming increasingly important as a means of dispute resolution in taxation. This training will deal with some recent developments in the field of litigation. It will start with an explanation of the cassation procedure with the Supreme Court in The Hague that was introduced two years ago. In that respect particular attention will be paid to the role and tasks of the Supreme Court and the analysis of decisions issued by the Supreme Court. During the training we will also elaborate on examples of local cases. In the second part of the training, the focus will be on the procedure with the courts of first instance and the court of appeal. Specific attention will be granted to key procedural issues such as providing evidence (e.g., the burden of proof and the use of witnesses). Of course, there will also be time for questions. This training will be given by Ronald Scharrenburg (PwC NL) and Arne Kattouw. Meet our main speaker Ronald van Scharrenburg. Ronald is heading PwC s tax litigation department in The Netherlands. He also is a deputy judge in the Court of first instance in Haarlem and a member of the expert committee on formal and procedural tax law of the Dutch Association of Tax Advisers. Before joining PwC in 2006, Ronald worked for several years for the Dutch Supreme Court. He has published various articles on international and domestic tax issues, including fiscal profit accounting and the (international) tax consequences of (intra) group financing. Date: Friday, 16 March 2018 Language: Dutch

2 Profit Tax This training provides you with an overview of the principle of sound business practice with regard to determining profit and how this relates to the issue of transfer pricing. We will have an in depth discussion of the most relevant aspects for determining the profit of your organization. The training will give an overview of the different methods of inventory valuation, fiscally accepted provisions, including selfmanaged pension schemes and the relationship between head office and permanent establishment. We will elaborate on the differences between debt and equity finance and financial versus operational lease. The training uses practical examples and the application of relevant jurisprudence. This training will be given by Arne Kattouw and Nicole Sillé. Date: Thursday, 22 March 2018

3 Blockchain Experience Blockchain is one of the eight different emerging technologies we should watch. It is expected that they will have a huge impact on our daily lives. In this training we will have a closer look at these emerging technologies and on Blockchain in particular. What is Blockchain Technology and what is its potential impact on your organisation? What are the possibilities and opportunities? During this training, you will get the opportunity to experience this disruptive but innovative technology yourself. The training will combine theory and practice. It starts with an explanation why there is such a buzz around Blockchain and an assessment whether it is realistic. Then we will explain the basics of Blockchain Technology, followed by a demonstration of some Proof of Concepts and use cases. In this session, we will assess the impact of Blockchain on current business models: from compliance solutions for tax fraud to improving the customer journey within the hotel sector. During the interactive part, we will play the game the Blockchain Experience, in which the participants will actually be the Blockchain themselves*. Furthermore, in small groups, we will work on identifying use cases that are relevant within your own sector or organisation. We will wrap-up the session by providing practical tips how to start exploring Blockchain within your own organisation. *An introductory version of the Blockchain Experience will be played. This training will be given by Christian Lieverse (PwC NL) and Fieke van der Vlist (PwC NL). Date: Friday, 20 April 2018 Location: Renaissance Hotel (Food and

4 Structuring Netherlands and Curaçao Structuring through Curaçao after the offshore era. The recent developments in international tax law have had an unprecedented impact on international corporate tax structuring. The actions and possible sanctions by the OECD and the European Union have also moved Curaçao to make further amendments in its tax legislation. In this course we will elaborate on the recent review of the Curaçao tax regimes by the OECD and the publication of the EU s grey list jurisdictions and anticipate on the further alignment of Curaçao tax regimes to the current internationally accepted and required standards. In addition we will discuss the alternatives for companies dealing with the quickly approaching end of the offshore regime. Furthermore, we will also discuss the recent reforms of Dutch tax legislation, specifically with respect to the Dutch dividend withholding tax. Lastly, we will elaborate on the tax structuring possibilities between the Netherlands and Curaçao based on different cases. This training will be given by Terrence Melendez and Mitchell Karman. Date: Friday, 18 May 2018

5 Reorganisations, mergers and tax due diligence This training provides you with an overview of tax aspects and pitfalls of sale and purchase of businesses, due diligence, restructuring and reorganizations. We will give you a holistic overview of the relevant fiscal aspects for the profit tax, turnover tax and real estate transfer tax. The training uses an analytical framework and real-world applications to introduce the key principles and techniques, such as the transfer within the fiscal unity, merger and demerger and business merger facility. We will elaborate on the fundamental tax differences of structuring an acquisition as a share purchase or an asset purchase, how to structure this acquisition as well as in-depth know-how about the various areas and pitfalls of tax due diligence. This training will be given by Lennart Huijsen and Harley Offerman. Date: Friday, 15 June 2018