IFA is very pleased to present its virtual programme with seven webinars to take place from 16 - 25 November 2020. The Main Subjects of this years’ Cahiers and IFA’s regular sessions will be held virtually on the IFA website and on the IFA App. Also IFA’s Young IFA Network (YIN) and Women IFA Network (WIN) will organise a virtual session, and you can visit the virtual poster programme. Through seven dynamic sessions, our experienced speakers will focus on important developments in the world of international taxation.
Apart from the opening event on Monday 16 November at 15.00 hours, and the closing event on Wednesday 25 November, the sessions will include:
The WIN Seminar will be held in memory of Carol P. Tello, President of IFA USA Branch.
The event will be opened by the IFA President, Murray Clayson and the President of the Cancun Congress, Edgar Anaya, on 16 November 2020, followed by a brief introduction on the scientific programme by the Chair of the PSC, Robert Danon. Also, the meeting of the General Council/General Assembly will be held during the virtual event on Wednesday 25 November from 12.00 - 13.30 hours (CET). The programme will be closed by the Chair of the upcoming 2021 Berlin Congress, Christian Kaeser, on Wednesday 25 November after the session on Recent Developments.
Registration is reserved for IFA members and without charge. The sessions will be live but to ensure these sessions are convenient for all participants across the globe, all sessions will be recorded and made available to participants, 24/48 hours after the session, t if they wish to access these at a later stage. To access the recordings go to My IFA.
Reconstructing the treaty network
David Duff (Canada) Daniel Gutmann (France)
Chair of the session: Liselott Kana (Chile)
Enrique Bolado (Mexico)
Mukesh Butani (India)
Johann Hattingh (South Africa)
Carmel Peters (OECD)
Anna Theeuwes (Netherlands)
Phil West (USA)
Secretary: Juan Carlos Trujillo (Mexico)
The Multilateral Instrument, or MLI, manifests a more comprehensive multilateral weave of connections to reconcile the harmonious application of countries’ income tax regimes including existing bilateral tax treaties. This session will assess its impact on the prevailing treaty network and tax treaty policy in general.
The MLI’s legal framework will be examined in light of its history. The experiences of countries with the MLI’s format and interpretation will be considered, as well as whether its scope and the manner in which it applies besides bilateral treaties, present constitutional issues associated with its effective implementation. The role and involvement of the Inclusive Framework in setting standards that underlie the MLI and its application are also discussed.
In this light, the session will address the general tendencies of tax jurisdictions in selecting among various options for applying the MLI, informed by practical examples and insights about underlying policy considerations and concerns, and the extent to which they may be shared among affected and potentially affected tax jurisdictions including in this regard the implications of countries not participating or not participating fully in the MLI . The session will conclude by looking forward to anticipating what the MLI foreshadows for tax relations among countries and with present experience what new issues may emerge.
Exchange of information: issues, use and collaboration
Armando Lara Yaffar (Mexico) Tatiana Falcão (Brazil)
Chair of the session: Christoph Schelling (Switzerland)
Reinhard Biebel (EU)
Huey Min Chia-Tern (Singapore)
Maria-José Garde (Spain)
Marnin Michaels (USA)
Xavier Oberson (Switzerland)
Secretary: Nereida Jäggi (Switzeland)
This session will address the current status of cross-border administrative assistance in tax matters and will consider experience with implementation of these initiatives taking account of peer reviews.
The panel will discuss issues related to exchange of information upon request, focusing on group and bulk requests, and examine the application of guiding principles, such as foreseeable relevance, subsidiarity and specialty.
The discussion will further focus on automatic exchange of information, in particular where financial accounts are concerned, and will look into a potential revision of the international standard. It will also include the standard providing for spontaneous exchange of information, specifically on tax rulings.
Finally, taking stock of recent technical developments, new technologies and products, an outlook on possible future policy direction will address areas of potential enhanced cooperation and also consider limitations set by other domains of the law, such as data protection and constitutional principles.
Moderator: Ana Claudia Utumi (Brazil)
Robin Chesler (USA)
Shefali Goradia (India)
Sheila Lawlor (Ireland)
Patricia Mongkhonvanit (UN)
Belema Obuoforibo (Nigeria)
Grace Perez-Navarro (OECD)
Monique Van Herksen (Netherlands)
Secretary: Fabiola Díaz (Mexico)
The WIN Seminar will be held in memory of Carol P. Tello, former President of the IFA USA Branch.
Despite the advances of the OECD and UN works on taxation of digital economy, some countries seem not to be waiting for the conclusion of these works and are advancing on implementation of digital tax measures. The purposes of this panel is to examine what types of measures countries are actually implemented in relation to income taxation, and how these measures are impacting on multinational companies working in digital economy markets.
Moderators: Claudia Suter (Switzerland) & Maikel Evers (Netherlands)
Giorgio Beretta (Italy)
Lucas de Carvalho (Brazil)
Mahesh Kumar (Singapore)
Anubha Mehra (India)
Elisangela Rita (Angola)
Karoline Spies (Austria)
Daniel Winnick (USA)
This year's YIN Seminar will be centered around the ramification of the current crisis. While there has been so much written about the measures Governments across the globe have taken, little has been said from a more forward-looking angle. The panelists at the YIN Seminar will dare to look into the crystal ball and consider what may be ahead of us. What will tax policies look like in the short-, mid- and long-term? How will these affect Governments, businesses as well as individuals and how do they contemplate (re-)acting? Will we see disruption stirred by any of the players in the international tax world? A survey conducted by YIN will provide additional insight.
Chair: Luc De Broe (Belgium)
Benjamin Angel (EU)
Johanna Hey (Germany)
Bob Stack (USA)
Rita Szudoczky (Austria)
Secretary: Jasper Korving (Netherlands)
The webinar aims to offer a comprehensive overview of the most important (mainly direct) tax and tax policy developments concerning the European Union since the 2019 IFA Congress. A focus is being made on selected issues of current interest and an outlook is given on forthcoming developments.
The webinar will begin with a presentation of the recent and ongoing tax policy projects undertaken by the European Commission (DG Taxation and Customs). Thereafter, the panel will discuss the recent judgments of the General Court on state aid and transfer pricing rules, in particular the cases of Fiat, Starbucks and Apple. In the last part of the presentation, the panel will discuss the policy options available to the European Commission to address the income tax challenges posed by the digitalisation of the economy and by the need for a minimum effective taxation of multinationals.
Chair: Stef Van Weeghel (Netherlands)
Barbara Angus (USA)
Liz Chien (USA)
Martin Kreienbaum (Germany)
Fabrizia Lapecorella (Italy)
Grace Perez-Navarro (OECD)
Gaël Perraud (France)
Achim Pross (OECD)
Sh. Rasmi Ranjan Das (India)
Pascal Saint-Amans (OECD)
Mike Williams (United Kingdom)
Secretary: Erisa Nuku (Netherlands)
The IFA/OECD seminar addresses several major developments in the international tax arena. It is comprised of two segments namely an OECD update and the tax challenges arising from digitalisation (Pillar One and Pillar Two). The first segment is intended as an update on the ongoing work of the OECD focusing on various OECD initiatives whereas the second segment delves deeper into the OECD’s work on digitalization and the challenges and opportunities arising therefrom.
Chair: Chloe Burnett (Australia)
Reuven Avi-Yonah (USA)
Shefali Goradia (India)
Adolfo Martín Jiménez (Spain)
Ana-Claudia Utumi (Brazil)
Scott Wilkie (Canada)
The Recent Developments panel will explore what is new in international tax. The latest case law from around the world will be reviewed, particularly in the areas of tax treaties and transfer pricing, and including fresh jurisprudence on issues underlying or illuminated by the BEPS measures. Developments in approaches to issues central to the multilateral “pillars” proposals will also be addressed. There will be debates and frequent interaction between the panellists and, as ever, late breaking news will be reported.