The IFA Regions in the spotlight
While many IFA members associate IFA with the Annual Congresses, IFA is much more than that. Its Branches are active on all continents. Bringing together tax advisors, government officials, academics, and other tax experts to discuss current developments, the network of local Branches is the lifeblood of our thriving community. In the past months they have organised regional conferences, attracting hundreds of IFA members. On the agendas where topics typical to the regions concerned, but one theme appeared to be a running thread in many of the discussions: the BEPS project.
With the deadline for delivery of September 2015 coming close, the possible impact of the project on international tax system is becoming clearer. Various regional IFA conferences discussed the possible impact on their region, covering questions such as: How will the countries implement BEPS in the wake of their double tax treaty obligations? What are the main consequences of BEPS in the various regions? And in the Benelux countries the question has risen if the investment climate will have the most impact from BEPS. A quick view on the work done and issues discussed in the IFA Regions.
IFA Asia-Pacific Regional tax conference held in Singapore: BEP’s caution
BEPS was one of the various current international tax issues discussed at the inaugural IFA Asia-Pacific Regional tax conference held in Singapore in April 2015. This first-time regional conference focussed on a number of BEPS issues including BEPS and the changing tax landscape, the digital economy, anti-avoidance measures, latest trends in the Asia-Pacific region and recent developments in the world of transfer pricing.
One of the highlights of the two day conference was the keynote talk on 'Source vs Residence' by Philip Baker (QC). Taking a step back from the detailed discussions in the BEPS project, he gave a full perspective on this fundamental issue. Explaining concepts of residence, source and BEPS in detail, Mr. Baker posed the central question: “What should be the basis for a jurisdiction to impose income tax”?
Panel discussions also shed light on countries like Korea, Indonesia and Australia turning the heat on MNCs even before BEPS comes into force. Singapore's Senior Minister of State for Finance - Ms. Josephine Teo, however cautioned against unilateral, un-coordinated action and asserted that it is critical for tax reforms to accommodate "legitimate business models."
For a full report on the IFA Asia-Pacific IFA Regional Conference, please click here for an extensive article IFA Special – Singapore, published in the Indian international tax journal Taxsutra.
The 9th Asia/Africa IFA (Mauritius) Conference 2015
BEPS was discussed in an African and Asian perspective during the 9th Asia/Africa IFA Conference held on the 7th and 8th May 2015 in Mauritius, focussing on the central themes, “Recent Developments in International Taxation” and “The Tax Challenges of Investing in Africa”.
In his address, Mr. Kaka stated that we are now living in an era of exchange of Information and referring to the automatic exchange of information, he queried how tax authorities would process such information. This burning issue was also dealt with by Prof. P. Shome, the Conference Chief Guest. He raised certain issues on the challenges faced by MNCs to do country by country (CBC) reporting. He was of the view that the whole purpose by the BEPS project is to end tax avoidance. However, he did raise doubts about how MNCs are going to cope with the new country to country (CBC) reporting challenge in light of the BEPS Actions.
For a full report on the IFA Asia/Africa (Mauritius) Conference, please click here: 9th Asia-Africa IFA Conference Mauritius 2015
The next regional Asia/Africa conference has been fixed to the 19th and 20th May 2016 The IFA Community Worldwide are invited to block out those dates and to come to Mauritius in May next year!
7th Latin American Conference
Also the 7th Latin American Conference held in Danto Domingo 20-22 May 2015 discussed BEPS and its impact. One of the topics discussed was the current status of double tax treaty models and the BEPS actions. This touched on the development of a Multilateral Instrument (Action 15) to help countries amend their bilateral tax treaties swiftly and efficiently in order to give effect to BEPS measures. Such a streamlined method to amend treaties can modify large numbers of tax treaties and may well prove to be one of the lasting consequences of the BEPS project.
A closer look was also given to a non-profit organisation outside IFA: The Inter-American Centre of Tax Administrations (CIAT) and its policies in times of BEPS. Mr. Manuel Tron (Honorary IFA President) and Mr. Marcio F. Verdi (General Secretary of CIAT) held an engaging dialogue on the CIAT and its policies in the times of BEPS. The CIAT supports the efforts of national governments by promoting the evolution, social acceptance and institutional strengthening of tax administrations, encouraging international cooperation and the exchange of experiences and best practices. Founded in 1967, CIAT currently has 38 member countries.
See photos of the event: http://ifasantodomingo2015.org/language/es/category/galerias/
Trilateral meeting Belgium-Luxemburg-Netherlands 12-13 June 2015
One of the three themes of the Trilateral meeting of the IFA Branches in the Benelux “Consequences of BEPS for the investment climate in each of the Benelux countries”. Their meeting took place on 12 and 13 June in Liege (Belgium), in a year in which there is much at stake for the countries concerned. Representatives from government, tax advisory and business focussed on a number of BEPS Action Items that were marked as most relevant for their countries.
Belgium, the Netherlands and Luxembourg are important hosts for investments by US multinationals. As the speakers expected that the BEPS project will have a considerable impact on these multinationals, they concluded that there may be a considerable impact on the Benelux countries as well. And if the impact does not come from the BEPS project immediately, the direct impact may come from Brussels. Speakers were concerned about the actions from the European Commission concerning legislative proposals and state aid procedures. Actions that require EU Member States to change their international tax rules, while third state would remain sovereign.
It was also noted that the governments of Benelux countries are each making great steps in improving international tax transparency, with the Dutch government even supporting public Country by Country reporting. Speakers did however expressed concerns about negative side effects of increased transparency and information exchange, including an increased number of possible disputes between taxpayers and tax authorities. It is also for that reason that the speakers and the audience at the trilateral meeting expressed their desire for improvement of mutual agreement procedures and mandatory arbitration.
For more information on past and future IFA Conferences, please visit our website.