SuBstance in International Tax Law

Transcription

1 Novotel Madrid Campo De La Naciones Faculty of Business and Economics (HEC) Faculty of Law, Criminal Justice and Public Administration 26 September 2016, IFA Congress Madrid SuBstance in International Tax Law Latest trends in anti-abuse and transfer pricing rules With the kind support of 3

2 OVERVIEW From a tax perspective, international transactions are often considered in light of their substance as opposed to their mere legal form. With some variations, the substance analysis is a distinct feature of domestic and international anti-abuse rules and also comes into play in the field of transfer pricing. Further, substance has now become a core principle of the post BEPS world. This seminar, which is formed by a panel of distinguished international tax experts, explores latest trends in the substance analysis. Based on two classical case studies involving share transfers, holding and financing structures, the panelists will discuss most recent developments, case law and practices relating to anti-abuse rules of selected jurisdictions as well as their relation with tax treaties and EU law. Potential conflicts and double taxation situations caused by domestic anti-abuse rules will also be examined. Next, particular attention will be paid to anti-abuse rules embodied in international instruments such as tax treaties and European tax directives. Finally, the panel will look at how post BEPS transfer pricing rules may affect holding and financing structures. The foregoing discussions will allow the panel to assess whether there is a need for further coordination among states when it comes to the application of substance based rules.

3 SCIENTIFIC CONTENT SPEAKERS In order of appearance 16H15 16H20 16H20-17H00 17H00-17H40 17H40-18H30 Introduction and presentation by the chair The substance analysis in share transfers and holding structures The substance analysis in financing structures Cocktail reception Prof. Dr. Robert Danon (Chair) Professor of Swiss and international tax law, Director of the Master of Advanced Studies in International Taxation and Executive Program in Transfer Pricing, University of Lausanne Dr. Vikram Chand Executive Director, Master of Advanced Studies in International Taxation and Executive Program in Transfer Pricing, University of Lausanne Prof. David Rosenbloom Director, International Tax Program, New York Law School SEMINAR OBJECTIVES : The seminar explores 1. latest developments involving anti-abuse rules 2. the relation of anti-abuse rules with tax treaties and EU law 3. Post BEPS transfer pricing rules SEMINAR AUDIENCE : The seminar is open to tax practitioners, member of tax administrative, academics & all other participants attending IFA Mr. Bruno Gibert Partner, CMS Bureau Francis Lefebvre Mr. Jean-Blaise Eckert Partner Lenz & Staehelin Prof. Guglielmo Maisto Professor of Tax Law at Università Cattolica del Sacro Cuore (Piacenza), Founding Partner, Maisto e Associati Mr. Jefferson Vanderwolk Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division, OECD

4 SUBSTANCE IN INTERNATIONAL TAX LAW LATEST TRENDS IN ANTI-ABUSE AND TRANSFER PRICING RULES SEPTEMBER 26, 2016, 16H15-18H30 Location : Novotel Madrid Campo de Las Naciones The venue is located only 4 minutes walking distance from the congress centre Luginbuehl Kylan UNIL. Map curtesy of Google Important: Please contact Natacha Fauconnier (Natacha.fauconnier@unil.ch) for any information regarding the event. FACULTY OF BUSINESS AND ECONOMICS (HEC) FACULTY OF LAW,CRIMINAL JUSTICE AND PUBLIC ADMINISTRATION Université de Lausanne Internef CH-1015 Lausanne Tél Fax

5 MASIT INTERNATIONAL TAX POLICY SEMINAR: Substance in International Tax Law Latest trends in anti-abuse and transfer pricing rules SEPTEMBER 26, H15-18H30 IFA Madrid, Novotel Madrid Campo de Las Naciones, c/amsterdam n 3, Madrid, Spain REGISTRATION FORM Mrs. Mr. Dr. Other Family name First name Function Company Street / Nr PO Box Zip code City Phone Nr Country I will participate (Free entrance) Important : Please your registration form no later than September 22 nd, 2016 to natacha.fauconnier@unil.ch Registration will be applied on a first-come first-served basis Confirmation : Upon receipt of your registration form, you will receive our confirmation. Cancellation : In the event of cancellation, written notification should be sent to : natacha.fauconnier@unil.ch I agree to the above mentioned conditions. I have read and accept the cancellation terms. Signature Date