Time & Location 

Tuesday 17 Nov. 16:00 CET - 24. Nov. 19:15 CET 

Platform: Zoom

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Pricing: Free

About the Event 

The increase of economic cross border activities, with business models being impacted by digitalization has shaped the way countries choose their tax policy. As a consequence, international tax competition has raised at a considerable level. With the intention to coordinate efforts, we see an expansion of international institutions involved in tax policy making but, nevertheless, having sometimes overlapping or conflicting guidelines and standards. While national tax policy tries to raise revenue by taxing what a country has access to, e.g. tourism, commodities and intellectual property, international tax policy should address taxation from a global perspective, limiting and sometimes clashing with a country’s specific aim. This creates uncertainty in the tax arena and can trigger a war on tax.

With this in mind, TPA Global is facilitating an online conference (program below) together with the GTC network that will enable tax practitioners to keep up-to-date with the most recent developments in the field of tax policy and controversy in international tax and transfer pricing.

In the first day the conference is focused on how technology changes the nature of disputes and how uncoordinated tax policies put multiple claims on the same profit. In the second day we invite attendees to discuss onshoring of intangibles and alternative dispute resolution replacing common dispute resolution. . In the third day we present the discussion on balancing between transparency and social responsibility and the impact of EU state aid cases on disputes. The format of the conference allows members to join break out rooms on diverse (sub)topics and participate in the general panel discussion.

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Platform of streaming: Zoom

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Days: November 17, 2020; November 19, 2020; November 24, 2020. 

AGENDA

Each day has two panel discussions for the whole audience and thereafter break out rooms facilitated by 1-2 specialists. 

Day 1 - November 17, 2020

16.00 – 16.15 Welcome message and introduction

16.15 – 17.00 Taxpayers’ rights: in the current tax policy and tax technology arena

17.00 – 17.45 Break out rooms - How technology changes the nature of disputes

Room 1 – How do tax authorities use data - the digital controversy war on tax 

Room 2 – Threats to taxpayers’ rights and further steps to improve taxpayers’ rights

Room 3 - Low risk distributors: A LATAM experience

17.45 – 18.30 Panel discussion: How to deal with extreme tax authorities’ positions?

18.30 – 19.15 Break out rooms - How uncoordinated tax policies put multiple claims on the same profit

Room 1 – Diversity of Safe harbors application

Room 3 – German case on nexus and WHT

Room 4 – Vodafone case in India

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Day 2 - November 19, 2020

16.00 – 16.15 Introduction

16.15 – 17.00 Controversy in the valuation of intangibles

17.00 – 17.45 Break out rooms - Onshoring of Intangibles

Room 1 - Transfer Pricing & Intangibles - Principles and practices for IP onshoring 

Room 2 - Value Chain & Intangibles - Which portion of residual profit to be allocated to intangibles

Room 3 - Lessons learned: court cases on intangibles

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17.45 – 18.30 Alternative dispute resolution tools: which ones are efficient and which are not 

18.30 – 19.15 Break out rooms - Alternative dispute resolution replacing common dispute resolution

Room 1 - The sustability of traditional APAs in the current scenrio

Room 2 - Scrutiny by Tax authorities positions across the globe - When to use ADR

Room 3 - HMRC's Guidance + "Real" Alternative Dispute Resolution cases

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Day 3 - November 24, 2020

16:00 - 16:15 Introduction 

16.15 – 17.00 Good corporate tax citizenship - the example of financial institutions

17.00 – 17.45 Break out rooms - Balancing between transparency and social responsibility 

Room 1 - The benefits of running a Corporate Social Responsibility program 

Room 2 - Being tax compliant guarantees a license to operate your business

17.45 – 18.30 EU state aid cases: is it time for reflection?

18.30 – 19.15 Break out rooms - Impact EU state aid cases on disputes

Room 1 - EU commission arm's length principle

Room 2 - The impact of Apple's General Court Decision

TPA Global has organized this conference in close co-operation with a group of independent tax litigators working together as part of a Global Tax Controversy network. 

For more information please contact

Yvonne Chin, email: y.chin@tpa-global.com or telephone: +31 20 462 3530

Ruzana Tunku, email: r.tunku@tpa-global.com or telephone: +31 20 262 2980

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Click here for the selection of profiles of facilitators for the above-mentioned sessions.