22 - 23 Apr 2021FIT/IBFD Joint Webinar Series – The Global Tax Landscape in 2021 and Beyond
We are pleased to invite you to the FIT/IBFD Joint Webinar Series – The Global Tax Landscape in 2021 and Beyond. This event is online and available to all our international tax friends and clients both within and outside India. The online conference is a two-day event and will cover four unmissable topics.
The registration fee for the two day event is USD 120.
- Online Event
- FIT/IBFD Joint Webinar Series – The Global Tax Landscape in 2021 and Beyond
We are pleased to invite you to the FIT/IBFD Joint Webinar Series – The Global Tax Landscape in 2021 and Beyond. This event is online and available to all our international tax friends and clients both within and outside India. The online conference is a two-day event and will cover four unmissable topics.The topicsWhere do we stand on digital tax? Possible options, challenges and the road aheadThe debate on digital tax is far from over! While the technical proposals for Pillar 1 and Pillar 2 await consensus, digital tax remains the focus of the international landscape in 2021, given the proliferation of unilateral levies with the widest form of economic nexus test. This is further exacerbated by US trade commissioner action against select jurisdictions under section 301, labelling them as discriminatory. The OECD is expected to unveil its progress report in 2021. This session will debate the developments at the international and select jurisdictional levels.Transfer pricing and ALP in a COVID world – A double whammy“COVID-19 is a slingshot into 2023”. MNEs have accelerated their digital transformation journeys and reinvented their supply chains and go-to-market approaches. These changes have profound transfer pricing implications, arising from all-new business models giving rise to new forms of transactions, such as remote working. Similarly, there have been disruptions that have played out differently in different sectors – technology and healthcare companies have come out stronger, while those in the conventional automotive and consumer-durables sectors have seen a decline in consumer spending. Deceleration in growth is expected to lead to a significant decline in earnings.The panel will address the OECD guidance on transfer pricing implications arising from COVID-19 and its implications for comparability analysis, allocation of costs and treatment of losses, effects of government assistance and impact on APAs.Dispute resolution – Update on AP 14 – A problem chasing a solutionIs the OECD’s Action 14 a minimum standard, and to what extent has its efficacy been played out? With growing MAP cases and the resolution process getting longer in recent years, has it served the purpose it was meant to serve? The OECD’s initiative to seek public consultation is seen as a welcome step towards facilitating improvement. What have country experiences been in the wake of improvements to the MAP process and the strengthening of bilateral APA processes? Will mandatory arbitration remain a dream, or will jurisdictions embrace other changes to make dispute resolution effective? The panel will debate the OECD guidance and the policy stances of select jurisdictions for improving the dispute resolution process.MLI – Rewriting the treaty network in the post-BEPS eraThe MLI requires jurisdictions to introduce anti-abuse rules in DTAs by way of a PPT or PPT with SLOB or to enter bilateral negotiations for a detailed LOB provision. Several optional provisions for dealing with PE abuse are mentioned in the MLI. Will these changes lead to reconstructing the treaty network? To what extent have they led to rewriting DTAs to the extent of covered treaties, and what have been the experiences of countries that have notified the synthesized versions of DTAs? How will the inconsistencies in those versions be dealt with? The panel will debate these nuanced issues of the MLI and its impact.
Day 117.30 .Opening address17.40Session 1: Taxing Digital BusinessesMultilateral Measures to Tax Digital Businesses
Technical presentations:Inclusive Framework – Pillar I proposals: Overview and analysisUN Tax Committee – Tax on Payments for Automated Digital Services: Overview and analysis18.10Taxing Digital Businesses – Trends Emerging from Unilateral MeasuresTechnical presentations:Global Overview of Unilateral MeasuresTaxing Digital Businesses – the Indian Experience18.45Panel discussion19.30Session 2: Transfer Pricing and ALP in a COVID World – A Double Whammy
Key Practical Challenges:Comparability analysisLosses and allocation of COVID-specific costsGovernment assistance programmesAdvanced pricing agreementsPanel discussionCloseDay 217.30Opening address
17.35Session 1: Dispute Resolution – BEPS Action Plan 14 – A Problem Chasing a Solution?Presentation on Action Plan 14: Key issues and controversies, including selected country issuesPanel discussion19.00Session 2: The Multilateral Instrument – Rewriting Tax Treaties in the Post-BEPS EraThe MLI, three years onTechnical presentations:The MLI in practice: A Global OverviewThe MLI in practice: The Indian experience19.30Interpretation and Application of the MLI – Selected IssuesPanel discussionPrevention of treaty abuseArtificial avoidance of PEsDual resident entities20.25Closing remarksAll times shown are Indian Standard Time (IST)
Day 1Prof. Guglielmo Maisto – Maisto e AssociatiMr TP Ostwal – Managing Partner, TP Ostwal & Associates LLP, Chartered AccountantsMs Vanessa Arruda Ferreira – IBFDMs Parul Jain – FIT, Nishith Desai AssociatesMr Akhilesh Ranjan – Advisor, Tax Policy, PwCMr Sanjay Tolia – Tax & Regulatory Leader, PwC IndiaMr Raffaele Petruzzi – Vienna University of Economics and BusinessMs Gabriela Capristano Cardoso – Vienna University of Economics and BusinessMs Shikha Gupta – Hindustan UnileverMr Graeme Wood – Director, Global Taxes, Procter & GambleDay 2Mr Mukesh Butani – Trustee, FIT (BMR Legal)Prof. Pasquale Pistone – Academic Chairman, IBFDMr Akhilesh Ranjan – Advisor, Tax Policy, PwCMr Sriram Govind – Advisor, Mutual Agreement Procedures, OECDMr Rahul Mitra – Senior Advisor, Transfer Pricing and International Taxation, M/s Nangia Andersen LLPMs Belema Obuoforibo – Director, Knowledge Centre, IBFDMr Ridha Hamzaoui – IBFDMr Padamchand Khincha – Partner, H C Khincha & Co, BangaloreProf. David Duff – Director, Tax LLM Program, University of British ColumbiaMs Ola Ostaszewska – Manager, European Knowledge Group, IBFD