Cross-Border Tax Disputes and Recent Cases
Concerns that tax administrations have had over aggressive international tax structuring in the post-BEPS era and the adoption of anti-abuse measures have led to increased scrutiny of cross border arrangements of multinational enterprises that are regulated largely by domestic tax laws and a wide range of tax treaties. The increased scrutiny has naturally led to more cross border disputes that are related to the application of international tax law embedded in domestic tax law and tax treaties, as well as the application of domestic and treaty anti-abuse rules. These cross-border tax disputes are emerging in all parts of the world and may be due to various reasons including information asymmetry, disagreement on the facts of a given case or different legal interpretations of the same facts as well as different interpretations of tax treaties.
This webinar will identify the common themes in cross-border tax disputes and discusses key recent cases from around the globe that may have a significant impact on the cross-border arrangements of multinational enterprises. It will cover a range of topics that may be the subject of cross-border tax disputes and recent cases, including those involving the application of anti-abuse rules, as well as the interpretation and application of tax treaties. Our instructors will share their practical experiences on dealing with such disputes and on managing their practical impact.
Block 1: Main cause of cross-border tax disputes in relation to corporate tax structuring
Block 2: Key recent cases on the application of anti-abuse rules
Block 3: Key recent cases on the interpretation and application of tax treaties
After this webinar, the participants will be able to:
- differentiate the causes of cross-border tax disputes in key recent cases
- identify the key principles established by these cases in addressing cross-border tax disputes
- compare and contrast the positions taken by different parties to the dispute
- assess the practical impact of the decisions of key recent cases
- Vanessa Arruda Ferreira, IBFD, The Netherlands (to be confirmed)
- Adam Zalasinski, European Commission, Belgium (to be confirmed)
- Shee Boon Law, Consultant, International Tax and Transfer Pricing, IBFD, The Netherlands
This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments:
- in-house tax professionals and advisers looking to assess main causes, trends and the impact of cross-border tax disputes in different regions and jurisdictions in relation to corporate tax structuring
- legal professionals assessing the risk of cross-border tax disputes associated with the interpretation and application of tax treaties and domestic tax law in different jurisdictions
- government officials involved in the interpretation and application of tax treaties and domestic tax laws regarding corporate tax structuring and anti-abuse provisions – particularly those responsible for auditing activities of multinational enterprises
This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and be familiar with the key concepts of international tax law.
No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.
On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.
If you have any questions regarding following the webinar, technical requirements, or payments and cancellations, please consult our FAQ.
Many accrediting organizations will grant continuing professional education (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.
International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE 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: www.nasbaregistry.org. NASBA CPE credit – 1 (only applicable to live webinar).
Field of study: Taxes
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.
