The subjects this year are:
Subject 1: Residency of legal entities for corporate income taxation.
General reporter:
Prof. Dr. João Félix Pinto Nogueira (Portugal)
Navigating the complexities of corporate tax residency in today's global economy presents a significant challenge for businesses and policymakers alike. IFA 2025 Main Topic One addresses tax residence, a fundamental yet often overlooked concept in modern corporate taxation. As globalization and digitalization accelerate, and the scope of domestic residency exponentially expands, the risk of triggering residency in multiple jurisdictions increases dramatically. Furthermore, the shift from "place of effective management" to mutual agreement as the treaty tiebreaker for dual residency conflicts exacerbates the potential for unresolved disputes, further endangering corporate survival as residence often triggers worldwide taxation. Whether you're a tax professional, a business leader, or simply interested in the future of corporate income taxation, this topic offers crucial insights into a matter of global relevance.
Subject 2: Improper use of tax treaties and source taxation: policy, practice and beyond.
General reporters:
Prof. Dr. Jinyan Li (Canada)
Prof. Dr. Eivind Furuseth (Norway)
The current mismatch between bilateral treaties and the global investment practices poses legal challenges in defining and addressing improper use of tax treaties. IFA 2025 Main Topic Two examines the complex and contentious issue of treaty abuse, where differences in domestic laws, treaty interpretation, and anti-avoidance measures create significant uncertainty for taxpayers and governments. As most jurisdictions adopt BEPS measures and the Principal Purpose Test (PPT), divergent approaches such as the U.S. reliance on limitation-on-benefits rules (LOB) underscore the lack of a unified standard. This topic explores how varying legal traditions, policy objectives, and dispute resolution mechanisms influence the interpretation, prevention, and resolution of improper use of tax treaties. The topic offers vital perspectives for tax professionals, policymakers, business leaders and investors.