International Tax Conference: Navigating Tax Complexities

2-3pm: A dispute resolution perspective.

OECD representative Jonathan Fraser will discuss the status of Pillar II, what controversy areas may arise around Pillar II and what dispute resolution mechanisms will be available for those controversies. He will also highlight the increasing importance of current dispute prevention tools and where they can be useful as self-help mechanisms to avoid Pillar II uncertainty and disputes.

3-3.50pm

Tax authorities around the world have become more assertive in recent years in their efforts to combat aggressive tax avoidance and improve compliance. But which countries are perceived to be stricter in their tax enforcement efforts?

During this session, our international tax experts will be joined by Feiza Jivraj of Macquarie to provide their insights on how aggressive tax authorities in their jurisdictions are and the key triggers that are likely to lead to a tax audit or enquiry.

4.15-5pm

Session A: Taxation of carried interest and management incentives: key trends and anticipated changes

Carried interest and management incentives remain a significant form of compensation for fund managers. These executives are increasingly based across Europe, in addition to traditional “head office” locations in the US and the UK. However, the rules governing carried interest and management incentives vary by jurisdiction, and their complexity and scope are often the subjects of ongoing discussions and potential changes.

In this session, our panel of experts will explore the key trends and anticipated changes in the taxation of carried interest and management incentives across different countries.

Session B: Controversy and dispute resolution observations for VAT and TP

Specialists from Italy, Ireland and the Netherlands will share insights into their experience with local dispute resolution, including controversy triggers in VAT and TP and how to prevent or manage them. They will discuss strategies for engaging with tax authorities across different jurisdictions and some of the ‘lessons learnt’ from past VAT and TP cases with HMRC's APA and MAP analyst Margaret Kayser.

5-6pm: Exploring the position in EU Member States post the CJEU Danish cases

The 2019 CJEU decisions in the landmark Danish cases provided important guidance on the concept of abuse under EU law and on the interpretation of the beneficial owner concept. This is particularly important in determining the availability of withholding tax exemptions/reliefs and treaty refund claims. The aim of this session is to explore what impact the Danish cases have had in practice on how Member States approach these subjects in applying tax treaties and EU Directives, as well as considering other local anti-treaty shopping measures.