In the after-BEPS-era it is clear that governments around the world do not consider it “fair” if taxpayers make use of structures to generate low or even untaxed income, even if these structures are in line with applicable law. In order to be able to find out which structures they consider fair or not, they are imposing more and more reporting obligations on taxpayers. But is it “fair” if the trust relationship between taxpayers and their advisors is jeopardized just to give these governments the opportunity to determine what they consider fair under rules they have created themselves? Does this take into account that if tax-free income is unfair, the taxation of the same income in two or more countries is also unfair? Is it fair if procedures introduced to avoid double taxation often do not, or only to a marginal extent, involve the taxpayer? If the current definition of a permanent establishment is not fair from the perspective of countries where only a substantial digital presence exists, would the broadening of such a PE definition be fair for the affected taxpayers?

These and other topics will be discussed during our first Global Tax Conference, taking place on November 21 2019, in Amsterdam. Should you arrive the day before, we would be delighted to also welcome you to our pre-conference dinner on November 20, 2019, 8 p.m. CET.

We hope you will join us.

Please confirm your attendance by October 31, 2019, by email to taxconference@dentons.com.

Event schedule

Registration and Welcome Coffee

10:00 – 10:45 a.m.

Keynote: Fairness versus Legality in International Taxation (Dr. Irma Johanna Mosquera Valderrama)

Unlike the former OECD projects that only provide for exchange of information between countries, the OECD focus in the BEPS Project on substantive issues that when implemented will change the international tax architecture of developed and developing countries. These initiatives aim to ensure that governments engage in fair competition and that multinationals pay their fair share. Even though these objectives are legitimate, these developments call for a new relationship between the taxpayer and tax administration considering mutual trust, legitimate expectations and respect for the taxpayers’ rights. Therefore, the main question addressed in this contribution is how to ensure that the new tax rules are consistent with the principle of legality and transparency (i.e. availability, clarity, simplicity, and reliability), so that the taxpayer is willing to comply with these rules?

10:45 – 11:15 a.m.

Panel 1: Mandatory Disclosure around the world

11:15 a.m – 12:30 p.m.

Lunch

12:30 – 1:30 p.m.

Breakout sessions

1:30 – 3:00 p.m.

• Real-time VAT reporting – another step towards transparent taxpayers?
• Resident non-dom regimes across the globe – pros and cons in international tax planning
• Global minimum taxation – the end of tax planning?

Coffee break

3:00 – 3:20 p.m.

Panel 2: Proceedings to avoid double taxation – how many roads do actually lead to Rome?

3:20 – 4:20 p.m.

Coffee break

4:20 – 4:40 p.m.

Panel 3: Digital Tax – the status quo and different possible scenarios

4:40 – 5:40 p.m.

Closing

5:40 – 6:00 p.m.

We are very much looking forward to seeing you in Amsterdam!