The finalisation of the BEPS project has provided governments with materials, tools and blueprints for reapplying the basic principles of international taxation like economic substance, permanent establishment and value creation. Yet it is far from clear how this large-scale project should be implemented: how to shape the new provisions so that they are fit for purpose? How can the implementation effort be coordinated internationally and achieve its political objectives? And how can one assure that the reconstruction does not lose sight of the taxpayers who are going to be subject to this new regime.
It will be crucial for both companies and tax authorities to clearly understand the concepts, and how they interact, in order to ensure that reasonable transactions are not deemed to be abusive:
- What level of economic substance will be required and how will this be reflected in practical terms, so as to determine where the key economic activities are actually being performed?
- What is the difference, if any, between value creation and economic substance?
- How can the spirit of the law be understood and interpreted in a consistent way in a cross-border context?
- What is the relevance of contract law, legal terms and interpretation in the field of transfer pricing (e.g., comparability analysis): will the above aspects have to change?
- What are the implications for VAT?
To be able to adapt successfully, taxpayers must be clear about the new rules.
Where traditional concepts are revised and tax rulings are under pressure, new ways of creating legal certainty and ensuring confidentiality must be explored.
9.30 Welcome by Henk Koller, President of the CFE
Introduction by Piergiorgio Valente, Chairman of the CFE Fiscal Committee
9.45 Session 1 - The EU and OECD Roadmap in Action - latest initiatives
- Moderation: Stella Raventós, Partner, ECIJA legal, Spain
Valère Moutarlier, Director, Directorate General for Taxation and Customs, European Commission; Grace Perez-Navarro, Deputy Director, Centre for Tax Policy and Administration, OECD; Ingo van Lishaut, Deputy Director Taxation, Ministry of Finance of North Rhine-Westphalia, Germany.
10.45 Panel discussions
11.15 Coffee break
11.45 Session 2 - Economic substance - What will change?
- Moderation: Ian Young, Chairman of the CFE Direct Tax Sub-Committee / Technical Manager International Tax, ICAEW Tax Faculty, United Kingdom
Vanessa De Saint-Blanquat, Movement of the Entreprises of France (MEDEF), France; Joachim Englisch, Professor, Institute of Tax Law, Westfalische Wilhems-Universität Münster, Germany; Martin Zogg, Attorney at law, Swiss Holding, Switzerland (TBC).
12.45 Panel discussions
14.15 CFE Award ceremony: Albert J.Rädler Medal
14.30 Session 3 - Certainty, confidentiality, transparency - What may taxpayers expect from administration?
- Moderation: Rupert Shiers Partner, Hogan Lovells, United Kingdom
Petra Pospíšilová, Chairwoman of the CFE Indirect Tax Sub-Committee / Tax Director, ČSOB Bank, Czech Republic; Isabelle Richelle, Professor, Tax Institute of the University of Liège, Belgium; Jeroen Lammers, Manager Policy Team Fiscal Affairs, Corporate Governance and Corporate Law, Association of Dutch Businesses, VNO-NCW, The Netherlands.
15.30 Panel discussions
16.00 Summary and concluding words by Piergiorgio Valente
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