IFA Conference: Practical aspects of the application of the double tax treaty between Germany and Poland

Kraków, Poland
24 September - 25 September 2023

Please join an upcoming conference, "Practical aspects of the application of the double tax treaty between Germany and Poland", organised by IFA Poland and IFA Germany. The event will take place in Kraków on September 24-25, 2023.
Language: English 


24 September 2023
19:00 Opening lecture and dinner

25 September 2023
10:00-11:00 Registration
11:00-11:15 Introduction to the event
Prof. Dr Christian Kaeser, President of the Board at IFA Germany
Dr Wojciech Sztuba, President of the Board at IFA Poland

Part. I. The most and least contentious provisions of the DTT DE PL
The long history of mutual investment, the movement of capital and people, and the creation of extensive supply and value chains have provided a rich test base for each of the provisions of the bilateral DTT. Which has worked well and caused the most disputes or difficulties?
• Permanent establishment concept changing over time (profit allocation, highly integrated business structures, VAT fixed establishment, temporary construction PE, remote work & new technologies, outsourcing trends
• Transfer Pricing and the evolution of TP methods
• Relocation of manufacturing functions to low-tax zones in PL
• Transparent entities LLPs, investment funds, trust contracts
• WHT / BO challenges and new duties

12:45-13:00 Coffee break

Part. II Polish-German practice on dispute resolution and dispute avoidance
The large number of disputes concerning the application of the DTT between Germany and Poland makes it possible to analyse the effectiveness of the available dispute resolution tools and assess their actual impact on economic relations.
• Practical application of MAP ( mostly disputed topics
• Resolution practice in transfer pricing disputes
• Dispute resolution vs. avoidance
• Tax ruling / APA practice in both countries
• Administrative information exchange

14:30-15:30 Lunch

Part. III. Impact of changes in the business and regulatory environment
15:30-17:00 Changing business models, remote working, e-commerce, the digitalisation of economies, the electrification of the automotive industry and the decarbonisation of industrial production. How will DTT PL DE deal with these and other future challenges? What changes to expected?
• Will both countries remain attractive investment sites for each other in the long run? What may change in the mutual lists of top investment advantages
• New definition of taxing rights as a result of Pillar One
• How mobility of work and automation may impact the future

17:00-17:15 Closing remarks
Prof. Dr. Hab. Krzysztof Lasiński Sulecki, Board Member at IFA Poland
Prof. Dr Christian Kaeser, President of the Board at IFA Germany


Registration fee is reduced for IFA members. More details about the event, registration and fees can be founded by link.


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