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ITR Managing Global Tax Disputes Summit 2019


Agenda


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8.00 REGISTRATION AND NETWORKING BREAKFAST

8.45 CHAIR'S OPENING REMARKS

9.00 KEYNOTE ADDRESS AND DISCUSSION: Latest from the OECD, EC and the in-house perspective

Regulators will update attendees on the source of various tax requirements implemented country-by-country. Our speakers will look at the latest tax controversies and interest areas in EU law - the impact of EC state aid decisions, the CJEU’s jurisdiction and tax developments.

  • Making dispute resolution more effective – tax treaty based MAPs and arbitration
  • Audit initiatives - are they running parallel or merging together?
  • EU (Dispute Resolution Directive)
  • Taxation of digital economy - OECD perspective and the unilateral actions in EU countries
  • Horizontal agreements and APAs

Achim Pross , Head of Division, OECD
Nicolas Rey , Case Handler – Tax Planning Practices, European Commission
Damon Lambert
, head of tax EMEA and indirect tax, Swiss Re Management
Erik Knijnenburg , Global Head of Tax & TP, H&M

9.50 PANEL NO 1: Transfer pricing and related tax dispute activities 

  • Anti-hybrid rules - when is the legislation being drafted and what structures are legit and covered?
  • Update on Hybrid Mismatch Legislation (BEPS 2); Interest Deductibility Limitation (BEPS 4); and EU ATAD2
  • Advance Pricing  Agreements (APA) - filing and concluding multilateral APA applications
  • Recategorisation issues for transfer pricing
  • Cross-border dispute resolution after BEPS

Yordan Nenkov , Head of Investment Tax, Partners Group AG
Yves Hervé
, Managing Director, NERA Economic Consulting
Martin Phelan , Head, William Fry Tax Advisors
Alistair Armstrong , Head of Tax, U+I

10.35-10.45 discussions on tables

10.45 NETWORKING TEA AND COFFEE BREAK

11.15 PANEL NO 2:  Tax authorities’ approach to international disputes

Experts from different jurisdictions are trying to draw some common features between jurisdictions, especially in light of case law and administrative approaches. Closer international cooperation must become necessary for the establishment of an international dispute resolution system.

  • Domestic remedies (settlement, litigation, unilateral adjustments etc.)
  • The limitation of domestic remedies in relation to cross-border tax matters
  • The use of joint audits to resolve disputes before they escalate
  • Should tax authorities in the resident state (of taxpayer) play a more active role?

Dr Arthur Pleijsier , Group Tax Director, Affidea
Samantha Dames , Tax Partner, CMS Cameron McKenna Nabarro Olswang LLP
Mario Martinelli
, Partner, CMS Adonnino Ascoli & Cavasola Scamoni
Carolina Graterol , Global Head of Tax and Transfer Pricing, Rosen Group

12.05 PANEL NO 3: EU state aid investigations

There has been a sharp increase in the number of EU state aid investigations and the challenges that relate to tax rulings between companies and EU member states. This coupled with an EU desire to eradicate the ongoing double tax issue. This session will look at state aid driven remedies for uncompetitive tax treatment which in turn give rise to tax disputes.

Nina Legaard Kristensen , Head of Unit, Danish Ministry of Taxation
Jean-Louis Barsac , Group Transfer Pricing and Regional Tax Leader, Nokia
Emmanuel Llinares , Managing Director, NERA Economic Consulting

12.55-13.05 discussions on tables

13.05 LUNCH

14.05 Tax arbitration in Portugal - an unconventional and effective tax dispute resolution model 

  • Main features and implementation of the Portuguese tax arbitration regime
  • Legal base and main goals
  • Material scope of tax arbitration tribunals on grounds of the case and the value
  • Arbitration administered by CAAD / Ethics Board
  • Prohibition from resorting to equity; simplicity and celerity
  • Publicity of the tribunal’s decisions - limitation to the appeal

Tânia Carvalhais Pereira , Head of Tax, CAAD - Centro de Arbitragem Administrativa

14.35 PANEL NO 4: Increasing tax certainty 1 - how to handle local vs international disputes

This panel will look at different approaches to dispute resolution and explore local v international approaches.  Our speakers share their experience of managing controversy in a different way - both experience with disputes involving cross border transactions in different countries and experience with purely domestic issues.

Shee Boon Law , head of knowledge - international tax group, DLA Piper
Jaime Salmerón Molina
, head of tax benelux, Repsol
Johanna Waal , tax director - large taxpayers office, Finnish Tax Administration

15.15-15.25 discussions on tables

15.25 NETWORKING TEA AND COFFEE BREAK

15.45 PANEL NO 5: Increasing tax certainty 2 - how is the in-house tax function adapting

The in-house tax function is changing - tax directors now need to understand flows of tax and accounting data in order submit online filings.

  • Tax certainty - how to manage risk and controversy
  • Monitoring and working together - the skills to deal with different countries
  • Dealing with disputes involving tax treaty countries
  • When and how to diffuse a difficult tax situation and manage expectations internally

Mark Houtzager , EMEA Tax Leader, Starbucks
Sangini Sewmangal , Global Head of Tax, Centrient Pharmaceuticals
Kim Boylan , Head - Global Tax Practice, White & Case
Brian Gleicher , Partner & Head Transfer Pricing Practice, White & Case
Steve Hayes
, Senior Vice President - Tax and Asset Management, Transocean
Daniela Steierberg , Global Head of Tax, Medac
Vineet Rachh , associate director – taxes, Procter & Gamble

16.30 MINI CORPORATE CASE STUDIES: Information symmetry and foreseeable developments in global disputes

Based on CbCR and information exchange between tax authorities, tax authorities can often have more information than the taxpayer. Our first case study speaker will give their perspective on how to pro-actively gather information from the business and how to deal with future disputes.  

Jean-Louis Barsac , Group Transfer Pricing and Regional Tax Leader, Nokia

Our second case study shares the recent experience of Maersk Tankers A/S in relation to tax disputes/audits concerning tax treaty benefits. Is there a knock-on effect with some tax authorities from the EU/BEPS-development on present interpretation and enforcement of existing legislation and tax treaties?

Jesper Howes , Head of Tax, Maersk Tankers A/S

Our final case study looks at the challenges of being a compliant taxpayer and what every company needs to consider.

Erik Knijnenburg , Global Head of Tax & TP, H&M

17.15 CLOSING REMARKS AND COCKTAIL RECEPTION

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