CFE Forum (21 April 2016): “Rebuilding international taxation: How to square the circle?”
The annual Forum of the Confédération fiscale européenne (CFE) on “Rebuilding international taxation: How to square the circle?” will take place on Thursday, 21 April 2016 from 9.00 – 16.30 hrs at the Representation of the State of North Rhine-Westphalia, rue Montoyer 47, 1000 Brussels.
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.
Please find all useful information in attachment
Deadline for registration: Monday 11 April 2016
Fiscalité > Internationale;Profession > Autres instituts ou fédérations