New Year's Letter IFA President

6 January 2020

Dear IFA Friends,

So we arrive at the first full working week of 2020. I hope that many of you will have enjoyed a restful break to conclude 2019 and can now look forward to an exciting and rewarding new year.

The Roman god Janus is typically depicted simultaneously looking both backwards and forwards. He was regarded as the god of time and also more curiously doorways, gates and passages. At any rate, he provides an excuse to look back to IFA’s flagship Congress in London, and forward to our Global Programme for 2020 – perhaps to be dubbed “2020 vision”.

In September in London we enjoyed the 73rd IFA Congress at the Royal Festival Hall. The two main subjects were Interest Deductibility: the Implementation of BEPS Action 4; and Investment Funds. There was also a terrific programme of seminars, including the ever popular IFA/OECD, IFA/EU and Recent Developments in International Taxation sessions, as well as less familiar but innovative topics such as the Taxation of Space and Tax and Sharia Instruments. The social and cultural programme included a reception at the National Gallery, a concert of British music through the centuries at St Paul’s Cathedral, a gin-infused YIN party at 100 Wardour Street and the closing Gala Dinner at the quintessentially English Hurlingham Club. The Congress was also notable for its inaugural WIN lunch which was hugely oversubscribed and had a buzzing atmosphere.

For the first half of 2020, we can look forward to our regional programme, as follows:
• Asia-Africa: 8-9 May, Mauritius
• Europe: 14-15 May, Milan
• Latin America: 19-21 May, Quito
• Asia-Pacific: 26-28 May, Hong Kong

We are also working on the next IFA Travelling Lectureship Programme which will be held across the Caribbean/Central America. The IFA Branch Development Fund will support an event in Brussels with our very welcome new 2019 Branch from the Democratic Republic of Congo. We will collaborate with IBFD in relation to an educational programme plus conference in Cameroon. And the David R Tillinghast Research Programme will inspire events in Singapore and South Africa.

At the conclusion of the London Congress, the IFA flag was ceremoniously handed over to Edgar Anaya, President of the forthcoming Cancun Congress. In Cancun the two main subjects will be Reconstructing the Treaty Network, and Exchange of Information: Issues, Use and Collaboration. Apparently we may expect a slightly less formal atmosphere than is traditional at our Congresses. I have been instructed that our conventional business attire dress code is being abandoned in favour of contemporary Mexican casual wear. Think guayabera.

Turning, then, to look backwards for a moment again, I remarked last year on the extraordinary rate of change in the world of international tax. The pace has only accelerated in 2019. The prominent “architectural” outputs have been the OECD/Inclusive Framework’s consultation papers on “Pillars” One and Two. When BEPS started, many were sceptical that real international consensus for change could be achieved. Few would have predicted the quite startling progress towards a “new taxing right” over remote business, and a global minimum rate of corporate income tax! There is now a sort of tense race on between proponents of the global solution (with some spice added by recent US reactions to Pillar One) and the proliferation of uncoordinated unilateral digital service taxes, with interesting consequential frictions upon trade and tariff discussions.

Some other important international developments in 2019 have included:
• further outputs from the supranational collaboration between the UN, OECD, IMF and World Bank, for example the draft toolkit on transfer pricing documentation and ongoing work on environmental taxation
• the expansion of the list of signatories to the Multilateral Instrument (MLI) to 93 countries, and the growth of the Inclusive Framework to 137 members
• an ever deepening programme of international exchange of tax information under the auspices of the Global Forum on Tax Transparency
• significant new EU case law in the tax/state aid area

Those of us who subscribe to international tax daily news feeds can expect that reports of important developments will multiply during 2020. It will be fascinating to watch the political and macro-economic currents affecting, for better or worse, the challenging path towards consensus on taxing the modern global economy. For sure, there will be plenty to discuss in Cancun.

There is one other important development on the IFA front to which I should draw your attention. Notwithstanding the prescribed informality for the Cancun Congress, members may nonetheless like to take a look at the new “Merchandise” page of the IFA website which displays our splendid new ties, scarfs and cufflinks.

With best wishes for a happy, healthy and successful 2020, and I hope to see many of you at the Congress in Cancun, tieless or otherwise.

Murray Clayson
International Fiscal Association