10th IBA London Finance and Capital Markets Virtual Tax Conference - Day 6 | International Bar Association (IBA) | 17 February 2021 | Virtual Conference

Global trends in tax controversy

This panel will bring perspectives from North and South America, Asia, and Europe, to a discussion of global trends in tax controversy. Potential topics for this panel include:
• Mutual agreement (MAP) and competent authority developments
• The impact of BEPS on enforcement and controversy
• Recent important decided cases that have multinational ramifications
• Information exchange issues, including CbyC, CRS, and FATCA, and their impact on enforcement and controversy
• The impact of the pandemic and recent political developments on tax enforcement and controversies

EU anti-abuse rules and beneficial ownership

Topics will include:

• The overlap of anti-abuse rules in investment structures: domestic GAARs, Parent Subsidiary Directive on dividends and on interest and royalties, ATAD and Tax Treaties.
• The impact of ECJ Danish cases in the interpretation of the Parent Subsidiary Directives.
• Is beneficial ownership an independent anti-abuse rule in addition to substance requirements and business purpose.
• Recent legislative, regulatory and judicial developments on beneficial ownership after ECJ Danish cases.
• Interpretation of the beneficial ownership concept.
• Beneficial ownership and Tax Treaties. Is beneficial ownership and implicit rule? Beneficial ownership beyond articles 10 to 12 MCOECD.
• Recent challenges on application of Tax Treaties and Parent Subsidiary Directive in private equity structures.

2021 Speakers

CHAIRS:

Phil West
Partner, Chair and Private Client Department Head, Steptoe & Johnson

Albert Collado
Partner, J&A Garrigues

SPEAKERS:

David Liu
International Partner, Duan & Duan

Raquel Novais
Senior Tax Partner, Machado Meyer

Dirk Pohl
Partner, McDermott Will & Emery

Luana Foffo Ciucci
Tax Group Director Southern & Central Europe, Procter & Gamble

Thierry Lesage
Tax Partner, Arendt & Medernach

Jakob Schilder-Knudsen
Partner, Lundgrens

Pieternel Verhoeven - van den Brink
Tax Lawyer, Nauta Dutilh

MODERATORS:

Walter H Boss
Partner, Bratschi

Aseem Chawla
Partner, ASC Legal

Reinout de Boer
Lawyer & Partner, Stibbe

Sam Kaywood
Partner, Alston & Bird

Carolina Rozo
Tax Partner, Philippi Prietocarrizosa Ferrero DU & Uria

David Shapiro
Partner and Co-Chair of Tax, Saul Ewing Arnstein & Lehr

Benjamin Twardosz
Partner, Cerha Hempel