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. On the other side, government are considering higher taxes in recent months to account for excessive spending on Covid-19 related matters. 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.
The first day of the conference is focused on how uncoordinated tax policies put multiple claims on the same profit, thus resulting in a variety of taxing claims on the residual profits. We will discuss how onshoring of IP leads to a host of tax disputes by observing how German tax authorities explore the boundaries of taxing IP (registration rights), but also the Dutch Uber case and the consequences of the migration of its IP to the Netherlands. Another crucial topic that will be touched upon is tax valuation of IP and what are the main arguments of tax lawyers on the valuation approach and variables when going to court. In the second theme during the first day, we will discuss whether there are any realistic propositions to (re)allocate residual profits after Pillar I has been abandoned or whether policymakers should go back to the drawing board. Other breakout sessions will look at the “inclusive members” perspective, as well as how to redefine “Amount B” in an approach to simplify worldwide transfer pricing rules.
Agenda Day 1 Wednesday May 26th, 2021
Each day has two panel discussions for the whole audience and thereafter break out rooms facilitated by 1-2 specialists.
Day 1 – May 26, 2021
16.00 – 16.15 Welcome message and introduction
16.15 – 17.00 How onshoring of IP leads to a host of tax disputes?
17.00 – 17.45 Break out rooms
Room 1 – Recreating nexus for intangibles
Case 1: How the German tax authorities explore the boundaries of taxing IP (registration) rights?
Case 2: The Dutch Uber case – will the migration of IP to the Netherlands lead to tax benefits?
Room 2 – What are the standard arguments pro and con on tax valuation of intangibles when going to court?
17.45 – 18.30 Panel discussion: What is the realistic proposition to (re)allocate residual profits after Pillar I has been abandoned?
18.30 – 19.20 Break out rooms
Room 1 – Rethinking Pillar I
Case 1: Pillar I the opposite to a consensus model – or how to go back to the drawing board?
Case 2: What is the position of the inclusive members – are they seeing benefits to stay onboard?
Room 2 – How to widen the ‘amount B’ definition under a consensus model – a road to Transfer pricing simplification?
Registration – https://www.gtc-global.org/gtc-virtual-conference-2021