Global Tax Conference

Everything everywhere all at once: The new era of Taxpayer's duties

Home
About Dentons - The Polycentric Law Firm™
News, events, awards
Events
Global Tax Conference

Global Tax Conference

Everything everywhere all at once: The new era of Taxpayer's duties

{0ACC201B-76BB-4128-A637-B2F3B3E23FD7}

Date and time:

Start: October 10, 2023, 10:00 AM BST

End: October 10, 2023, 6:30 PM BST

Location:
Convene 22 Bishopsgate
London
EC2N 4BQ
United Kingdom

3 shades of Tax Grey

The tax world seems to be moving at an ever-faster pace. Tax practitioners are confronted not only with local tax laws, but also with numerous initiatives on an EU and global scale. Pillar 1 and 2, ATAD 3, DAC-7, FASTER and BEFIT are just some of the acronyms that tax practitioners need to keep in mind in the context of international structures.

Most of these initiatives aim at making taxation "fair" but all of them come at the cost of additional duties to the taxpayer. Additional reporting obligations, filings, calculations and documentation – everything comes up everywhere and all at once! Sometimes taxpayers have finished their calculations for the escape clause of one initiative, only to realise that this initiative has been replaced by yet another one.

If this sounds familiar to you, attendance at our conference is a must!

Programme

Tuesday, 10 October 2023

Time	Activity
10:00 – 10:30 am	Registration and Welcome Coffee
10:30 – 11:00 am	Keynotes Keynote speakers: Erik Stessens, Senior Vice President, Tax – International Markets, Mastercard
11:00 am –11:45 am	Panel 1 Pillar 2: The New Era In this panel session, we explore the roll out of Pillar 2, what businesses think of it, and whether it is going to deliver on its objectives. Panel Lead: Alex Tostevin, Partner, Dentons, London Panellists: Erik Stessens, Senior Vice President, Tax – International Markets, Mastercard Jurjen Bevers, Partner, Dentons, Amsterdam Michał Bernat, Managing Counsel, Dentons, Warsaw
11:45 – 12:00 pm	Break
12:00 - 12:45 pm	Panel 2 ESG: Is it green to be double taxed? Fingers have been pointed at MNEs for their tax behavior. Their tax status is no longer a reserved matter for tax authorities. It is now under scrutiny by new players in the field, such as media, NGOs, activists, public prosecutors, workers councils. For them, ethics and morality are now expected as a must. What exactly does this mean? Is there a definition or quantum of what is ethical? And what level of disclosure should be used when this information be spread out by MNEs? Is tax transparency the new normal? Content: ESG related compliance obligations, new ESG shaped tax communication new players in the equation (media, NGOs, workers’ councils, public prosecutors) pacifying relationships with Tax is there a minimum decency global tax level? professional liability of CFOs and Heads of tax in a living tax environment Panel Lead: Sandra Hazan, Partner, Dentons, Paris Panellists: Philippe Blondiaux, Global CFO, Chanel Maurine Phelouzat, International Tax Director, Richemont Linda Pfatteicher, Partner, Dentons, San Francisco
12:45 – 2:00 pm	Lunch break
2:00 - 2:45 pm	Panel 3 International Structures in the new era – Taxpayer certainty, Authority action and Tax competition The OECD's efforts are driving convergence in international tax rules. However, the actual implementation and degree of uniformity will ultimately depend on individual jurisdictions' adoption and enforcement. Inevitably, differences will still exist due to diverse national priorities, economic circumstances, political decisions, and tax competition. National courts and tax authorities will continue to play a pivotal role in shaping fiscal policy, adding layers of complexity to an already intricate landscape. This means that business needs to respond to this rapidly shifting terrain and ensure it pays attention to a nuanced friction; balancing compliance with emerging international initiatives whilst staying attuned to local court rulings and tax authority sentiments. What impact has BEPS had on how tax authorities are scrutinising current structures and strategies? Will the Pillar developments stabilise international tax systems and facilitate tax certainty for taxpayers and tax administrations? In what ways are tax authorities collaborating internationally to combat aggressive tax planning? To what extent are certain jurisdictions pursuing their own independent approaches in contrast to global initiatives? Panel Lead: Alex Thomas, Partner, Dentons, London Panelists: Alex Hent, VP Tax & Treasury, Deliveroo Mariella Caruana, Tax Policy Advisor, BusinessEurope Chun Ying Ng, Partner, Dentons, Singapore Mark Galea-Salomone, Senior Associate, Dentons, London
2:45 - 3:15 pm	Coffee break & networking
3:15 - 4:15 pm	Breakout sessions Session 1: Impactful changes in the EU VAT landscape The EU VAT landscape is constantly changing. As the world becomes more digital every day, so does VAT. ln various countries we see new VAT legislation anticipating on this digitalized world (for example e-invoicing. However, not only new legislation but also new ways of doing business and case law anticipating on this. In this session, Sebastiaan Wijsman and Mateusz Machalski will guide you through all major changes and developments by means of recent European Court of Justice case law, practical guidance, and relevant legislation. This breakout session will address the latest VAT challenge and opportunities, with a focus on the platform and e-commerce economy, VAT recovery and VAT fixed establishments. Panellists: Sebastiaan Wijsman, Partner, Dentons, Amsterdam Mateusz Machalski, Counsel, Dentons, Warsaw Esther Hazenoot, Associate, Dentons, Amsterdam Session 2: Tax risk insurance in the new era Increased aggression from tax authorities, additional disclosure regimes, and new international rules; we discuss the impact of these on tax insurance, market trends and navigating the ever more challenging environment. Panellists: Alex Thomas, Partner, Dentons, London Dr. Andreas Berberich, Partner, Dentons, Munich Alex Tostevin, Partner, Dentons, London Dariusz Stolarek, Partner, Dentons, Warsaw Session 3: How can we report what we have to? This session will consider recently introduced and upcoming tax reporting obligations and the challenges businesses face in complying with these new rules. Does the business need to collect information it doesn’t already hold and how will it do this? What stakeholders are affected and how can the relationships be managed? Are product or contractual changes required? Do we have the resources for all of this? These are among the questions faced by businesses dealing with the various initiatives aimed at increasing the quality and quantity of data held by tax authorities. This session will consider these questions and practical issues around some of the latest EU and global tax reporting initiatives. Panel Lead: Niamh Keogh, Partner, Dentons, Dublin Panellists: Linda Pfatteicher, Partner, Dentons, San Francisco
4:15 - 4:45 pm	Coffee break & networking
4:45 - 5:30 pm	Panel 4 International Structures in the new era – What’s on the horizon? Cross-border investments and transactions are undoubtedly on the radar screen of tax authorities. The various OECD, EU and domestic initiatives (ATAD 3, SAFE, BEFIT to name a few) bear witness to the intensified scrutiny of such investments and transactions by governments worldwide. What’s on the horizon? Which organizations and groups will be driving changes? Will all those initiatives pose risks only for investors wanting to set up cross-border structures? Are there any benefits for the international business community? This panel will discuss those new developments and related questions for multinationals and cross-border investors. Panel Lead: Cezary Przygodzki, Partner, Dentons, Warsaw Panelists: Dr. Filip Majdowski – Counsellor to the Polish Ministry of Finance on international tax affairs, member of the OECD Steering Group on BEPS 2.0 project (Pillar 1 and Pillar 2) Simon Clubbs, Head of Tax, Segro Heico Reinoud, Partner, Dentons, Amsterdam John L. Harrington, Partner, Dentons, Washington DC
5:30 - 5:45 pm	Break
5:45 - 6:30 pm	Panel 5 Transfer Pricing Duties and Controversy in the new era In a global economy where the stakes are high, join us in discovering strategies to navigate intercompany transaction complexities, mitigate risks and enhance collaboration with tax authorities. Our distinguished panel of industry experts are ready to share their knowledge, experiences, and key strategies in dealing with transfer pricing duties and controversy in the new era. This panel discussion will address the latest transfer pricing challenges and opportunities with a specific focus on dispute prevention and resolution, including: Industry update: recent trends, developments and experiences Key strategies and tactics on preventing and resolving transfer pricing disputes How transfer pricing audits are evolving regarding complex matters Negotiation strategies getting to “yes” in MAP and APA procedures Main challenges in transfer pricing litigation Panel Leads: Dagmara Cisowska, Counsel, Dentons, Warsaw and Sebastian Frankenberg, Counsel, Dentons, Amsterdam Panelists: Olga Shambaleva, Global Direct Tax & Transfer Pricing, Lipton Stefano Marconi, Global Tax Senior Director, Amplifon S.p.A. Raymond Runtuwene, Associate Director Transfer Pricing, Genmab Rezan Ökten, Partner, Dentons, Amsterdam
6:30 – 6:40 pm	Closing
from 6:40 pm onwards	After Conference Food & Drinks