01 - 02 Jun 2017Current Issues in Outbound Investment for US MNEs in the Post-BEPS Era
This course focuses on challenging international tax issues that US multinational enterprises (MNEs) are facing in their outbound investment activities from a European perspective. While providing an in-depth analysis of practical implications from those changes driven by the OECD BEPS Action Plan and new developments in international tax law in favoured European countries, the course seeks to answer such questions of US MNEs as: (1) how to change the outbound investment strategies, (2) how to turn the challenges into opportunities and (3) how to prevent tax disputes with European tax authorities.
Early Bird Discount: a 30% discount will be applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
- Current Issues in Outbound Investment for US MNEs in the Post-BEPS Era
Course LocationThis course will be held at the IBFD Office for the Americas in Tysons Corner, Washington DC Metro area.
Overview and learning objectivesThis two-day course explores the outbound tax planning issues confronting US MNEs that operate in a number of jurisdictions around the globe. Topics to be addressed in this course include the practical implications of the OECD BEPS Action Plan in relation to intangibles, intra-group holding and financing structures, and transfer pricing documentation. The discussion extends its focus to the new developments in international tax law of the selected European countries favoured by US MNEs, and the recent investigation on EU State aid. It further considers tax risk management and prevention of tax disputes with European tax authorities.The course has been specifically tailored to meet the practical needs of tax, finance and transfer pricing professionals working in a variety of industrial and service sectors. By covering practical examples and a comprehensive case study, the course intends to provide new insights into risk factors associated with the way in which US MNEs do business in European countries in the post-BEPS era.Prior to the course, participants will be given access to online supplementary material (e.g. legal documentation, case law and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.
Who should attend?The course is suitable for finance and tax personnel of MNEs, tax accountants, lawyers, in-house tax managers, tax and transfer pricing advisers.
Course level and prerequisitesThis is an intermediate-level course. Participants taking this course are expected to be aware of the common international tax planning techniques. However, although prior experience of tax treaties and transfer pricing is desirable, it is not a prerequisite to satisfactorily participate in this course.
Pre-course preparationIn order to participate in this particular course, no advance preparation is necessary. However, for some courses, suggested reading materials will be made available on our documentation platform a few weeks before the start of the course.
Interactive course - "Group Live"To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 40 participants will be accepted. Early registration is therefore recommended.
Continuing Professional EducationRecommended CPE points for this course: 12 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.
Course fee and registration detailsThe course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance at the course, travel arrangements, payments and cancellations, please consult our FAQ.
- Setting the scene
- New challenges in offshore migration of intellectual property
- Future of intra-group holding and financing structures
- A close look at future development and risks in selected European countries: Netherlands, Ireland, Luxembourg and Switzerland
- EU State aid action against US MNEs
- Country-by-country reporting (BEPS Action 13)
- Managing tax disputes and resolution
- Wrap-up and conclusions
- Case study