Post-BEPS holding, finance and IP Companies in international tax structuring

This webinar explains the impact of OECD/G20 BEPS Action Plan on common international tax structures for holding activities, financing arrangements and intangible-related activities. Our instructors will share their practical experiences of dealing with the implementation of the actions in the OECD/G20 BEPS Action Plan, and look at how things might change under BEPS 2.0.

Topics Covered

Block 1: OECD/G20 BEPS Action Plan and Corporate Tax Structuring
  • An overview of the OECD/G20 BEPS Action Plan and the potential Impact of each action items on common tax planning structures for holding activities, financing arrangements and intangible-related activities
Block 2: Post-BEPS tax structuring considerations
  • Holding companies – impact of CFC rules, principal purpose test, harmful tax practices, etc.
  • Financing companies – impact of interest limitation rules, anti-hybrid rules, etc.
  • IP companies – impact of actions 8, 9 and 10, etc.
  • Transparency considerations in tax structuring
Block 3: Cases and Examples
  • Examples on the application of BEPS Action Plan to tax structures
  • Quizzes: identify adverse impact of BEPS Action Plan and BEPS 2.0 on existing tax structures

Learning Objectives

After participating in this webinar, you will be able to:

  • Associate various actions in the OECD/G20 BEPS Action Plan with common international tax planning structures;
  • Assess the impact of OECD/G20 BEPS Action Plan on common tax planning structures;
  • Apply the post BEPS requirements to a holding company, finance company and IP company; and
  • Determine the changes needed to international tax planning structures following the OECD/G20 BEPS Action Plan and the anticipated changes under BEPS 2.0.

Instructors

  • Tigran Mkrtchyan; International Tax Consultant
  • Shee Boon Law; Consultant, International Tax and Transfer Pricing
  • Francesco de Lillo (facilitator); Managing Senior, European Tax Knowledge Team

Field of study

Taxes
 

Who should participate

This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments, including:

  • In-house tax professionals and advisors looking to asses the impact of the implementation of OECD/G20 BEPS Action Plan
  • Legal professionals assessing the risk of tax controversy associated with international corporate tax structures for holding activities, financing arrangements and intangible-related activities
  • Government officials involved in the implementation of OECD/G20 BEPS Action Plan and those responsible for auditing international corporate tax structures

Course level and prerequisites

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 are familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

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

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. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 28 March 2023

On-demand webinar

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.

Continuing Professional Education

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 continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have 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).

Webinar registration details

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