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WebinarWebinar: Substance in International Tax Planning

This approximately 1.5-hour interactive webinar is the first of two webinars that will be dedicated to substance, the increasingly important notion of international taxation and transfer pricing.
EUR 85 / USD 105 (VAT excl.)
Client offer:
Client offerIncluded in the subscription package for Global Tax Premier clients and 10% discount for Global Tax Explorer (Plus) clients.
Bulk discount: a 20% discount will be applied to registrations received for 5 people or more made in one order. 
Please note: Registrations to the live webinar will be closed 3 days prior to broadcast and/or when the maximum number of registrations has been reached. Webinars can only be purchased by credit card.
Webinar: Substance in International Tax Planning

Overview and learning objectives

The webinar will help participants identify and interpret substance requirements and bring forward relevant court cases and guidelines from tax administrations. The webinar will also explore how companies can manage and comply with substance requirements in practice, in relation to both domestic tax law and double tax treaties. The OECD (BEPS and MLI) and EU law aspects of substance (stemming from EU Directives and relevant case law from the Court of Justice of the European Union (ECJ)) will also be covered. The second webinar on the topic of substance, Managing Substance in Transfer Pricing, will complement this webinar by explaining the importance and practical consequences of the notion in the realm of transfer pricing. 

Topics to be discussed in this webinar include the relevance of substance, and the interpretation and ramifications of the notion in relation to tax residence and anti-avoidance measures such as CFC, beneficial ownership, limitation on benefits clauses (LOB) and GAARs. Instructors will also explain the importance and application of substance for EU law and the lessons corporates can learn from substance-related ECJ case law. Emphasis will be placed on helping the participants make their international tax structures substance compliant and on highlighting the risk the new substance requirements entail for their structures, arrangements and transactions.

After following this webinar, you will be able to:

  • identify substance requirements in domestic and international tax law;
  • define the scope of the requirements and manage compliance with them
  • apply the guidance laid down by tax administrations, courts and international organizations.

Field of study


Who should participate

The webinar is suitable for all tax professionals including accountants, in-house tax personnel (e.g. directors, managers), lawyers and tax advisers who deal with cross-border transactions, structures or cases and wish to understand the risks, challenges and controversies related to substance requirements in the post-BEPS world.

Course level and prerequisites

This is an intermediate-level webinar. Participants taking this course are expected to be aware of the common international tax planning techniques and the practical problems related to them. 

Advance preparation

Participation to this webinar does not require any preparation.

Interactive webinar – “Group Internet Based” (live webinar only)

To safeguard the interactive nature of the webinar, a limited number of participants will be accepted. Early registration is therefore recommended. During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions or to complete short tests. Participants will also have access to the on-demand version for a further 12 months from the live date.
Date of live broadcast: 1 March 2018.

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation or assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant CPE credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.

The International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors.  State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit.  Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBA possible CPE credits - 1.5 (only applicable to webinar watched live).

Webinar registration details

If you have any questions regarding following the webinar, technical requirements, and payments and cancellations, please consult our FAQ.

  • Setting the scene
  • Substance and tax residence
  • Substance requirements in anti-avoidance rules
  • EU law and substance
    Tamás Kulcsár is a Manager at IBFD’s Tax Services team, as well as contracted expert of the IMF, with over ten years of experience in international tax, transfer pricing and VAT...
  • Premkumar Baldewsing 
    Premkumar Baldewsing is a Principal Research Associate at IBFD. He has extensive experience in the (inter)national tax arena, including in senior in-house tax functions with financial...
  • Emma Barrögård is a Senior Research Associate at IBFD Tax Services. She is involved in tailored tax research projects and in the development of tailored and open courses for tax...