TPA Global Webinars 2017

“Increasing controversy for offshore structures after BEPS”

A presentation on increasing controversy for offshore structures after BEPS.

Offshore (tax) planning structures have been used by multinational enterprises (MNEs) for decades. After BEPS, the artificial offshore structures that lack significant people functions are under attack as an increasing number of governments around the world are pursuing initiatives to prevent BEPS. This can be seen in the U.S. Senate hearing on the offshore structure employed by Caterpillar Inc., a giant in the construction equipment industry, the EU State Aid investigation into the use of Irish subsidiaries by Apple Inc.  and the UK Public Accounts Committee hearing into the structure of Amazon involving a Luxembourg holding company.

Most recently, the Australian Tax Office (ATO) has issued a Practical Compliance Guide (PCG) that sets out the ATO compliance approach to transfer pricing issues related to offshore centralized operating models (hubs) asking MNEs to conduct a self-assessment in this regard.  This places a clear pressure on the MNEs to take a proactive role in understanding the impact of their (tax) structures and ensuring their alignment with the operating models of their businesses.

Thus, TPA Global is initiating a series of webinars covering the global impact of these emerging BEPS developments on offshore structures. In the first webinar of this series, we will analyze the impact of applicable BEPS Action points on offshore structures from a global/OECD perspective and present some live cases impacted by these Action points and will end with recommendations to companies in similar situations. The subsequent webinars of this series

Key Highlights of the webinar

  • Presentation of the following elements of BEPS dealing with offshore structures:
    • Action 3 – CFC rules
    • Action 5 – Harmful tax practices
    • Action 6 – Principal Purpose Test/ Limitation of Benefits
    • Actions 8 – 10 – Allocation of risks and intangibles in line with significant people functions
  • Presentation of the impact of BEPS Action points on offshore structures through three current running cases of family owned businesses:
    • Singapore Procurement Office
    • Hong Kong product development office
    • Taiwanese production office under Hong Kong holding in combination with Dutch innovation box


Prof. Dr Hans van den Hurk

- Independent tax Advisor for Cygnus Tax
- Professor of International Tax Policy/Strategy, Maastricht University, The Netherlands

Wednesday, 27 September 2017

9.00 AM - 10.00 AM Mexico, USA and Canada
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
5:00 PM - 6:00 PM Moscow (MSK)


"Your Tax Technology plan"

In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden. This, coupled with escalating disputes in numerous locations across the globe, leaves limited opportunities for cost savings and tax optimization. In this light, many CFOs have indicated to TPA that they need to be on a path from ‘staying out of trouble’ to ‘being in control’.  

With this background in mind, it is crucial to increase efficiency of your organization through standardization and harmonization of processes, workflows and people. This can be efficiently executed only by automation through application of software solutions or by getting an “ERP on tax” fully implemented. However, depending on the business configurations, in-house organizational set-up, internal governance and compliance requirements, the applicable software solutions will vary considerably from one organization to the next.

So, what is your tax technology plan for FY2017-2018?

Our webinar will assist you in delivering a ‘being in control’ statement and getting started with your tax technology plan catered specifically to the requirements of your organization and people.

During the webinar, the following topics will be covered:

  • How to get your in-house organization and governance set-up BEPS-ready;
  • How to create and implement your tax technology plan;
  • How to choose the most suitable tax technology solution.


Avisha Sood
Associate, TPA Global
The Netherlands
Maria Grigoryeva
Associate, TPA Global
The Netherlands

Monday, 2 October 2017

9.00 AM - 10.00 AM Mexico, USA and Canada
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
5:00 PM - 6:00 PM Moscow (MSK)


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3 October 2017
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5 October 2017

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