11 April 2018, 12:30 -
13 April 2018, 15:30
The 18th Annual Tax Planning Strategies – U.S. and Europe will focus on practical planning strategies for multinational corporations and their international advisors, as well as provide insight into how government tax officials may view the international tax landscape in light of important international developments that impact corporate taxpayers.
Designed for international tax professionals from industry and private practice, sessions will cover:
- the impact of BEPS on multinational planning;
- the impact of U.S. tax reform on international structures;
- Pan-European investment structures as platforms into EU investment;
- the practical aspects of dealing with the MLI;
- new real estate structures and trends;
- mergers and acquisitions spins and interesting transations;
- treaty anti-abuse provisions;
- transfer pricing disputes;
- implications of state aid cases and OECD transfer pricing guidelines;
- and the digital economy -- new tax treatment from the EU and the U.S. response.
Panelists will include industry leaders, senior government officials, and leading tax practitioners from the United States and Europe.
As in past years, the Conference will be supplemented by half-day Private Wealth Management and Tax Executives Workshops on Wednesday, 11 April. Numerous networking opportunities will be provided and a conference reception will be held on Thursday after the last panel.
12 april 2018 / 1600 – 1730 Concurrent Session A
ATAD 1 and 2 with Particular Focus on GAAR and Hybrid Mismatches
In July 2016, the Council of the European Union adopted the Anti-Tax Avoidance Directive (“ATAD 1”) thereby implementing the outputs of the OECD Action Plans against Base Erosion and Profit Shifting (“BEPS”) throughout the EU. In May 2017 the Council adopted an amendment thereto (ATAD 2) extending the scope of ATAD 1 in respect hybrid mismatches to non-EU counties. ATAD 1 and ATAD 2 include, inter alia, a general anti-abuse rule (“GAAR”) and a rule aimed at neutralizing hybrid mismatches (both hybrid instruments and hybrid entities), to be implemented by EU Member States before 1 January 2019 and for hybrid mismatches involving non-EU countries, before 1 January 2020.
The panel will focus on the implementation of the GAAR and the hybrid mismatch rule as included in ATAD 1 and ATAD 2 in various EU-countries and the impact on US multinational planning. Also the recent US legislation based on the OECD BEPS Project encompassing hybrid mismatches will be discussed.
Peter H. M. Flipsen, Simmons & Simmons LLP, Amsterdam, The Netherlands
Carol Tello, Eversheds Sutherland (US) LLP, Washington, DC, USA
Michel Collet, CMS Francis Lefebvre Avocats, Paris, France
Ailish Finnerty, Arthur Cox, Dublin, Ireland
Riccardo Michelutti, Maisto e Associati, Milan, Italy
Martin Nillson, Mannheimer Swartling, Stockholm, Sweden
Dirk Pohl, McDermott Will & Emery, Munich, Germany
Christian Wimpissinger, Binder Grösswang, Vienna, Austria