Substance requirements in post-BEPS international tax planning
Following the implementation of the G20/OECD BEPS Action Plan, international tax planning practices have gone through a seismic shift where substance has taken centre stage. Substance requirements in post-BEPS international tax planning are becoming more and more complex as countries introduce minimum requirements for intermediate companies, substance requirements for incentive regimes, anti-abuse rules tackling lack of substance and transfer pricing rules with the requisite substance in terms of functions, assets and risks. The substance requirements in international tax planning are likely to evolve further under the Two-Pillar solutions. This webinar will explore how multinationals and tax authorities ought to look at the multifaceted substance requirements in international tax planning and the expected evolution of these requirements in the future.
- Block 1: Different types of substance requirements
- Block 2: Substance requirements in different types of tax planning structures
- Block 3: Risks and substance
After this webinar, the participants will be able to
- Differentiate between different types of substance requirements, including those associated with anti-abuse rules and the arm’s length principle
- Identify the substance requirements for different types of cross-border corporate tax planning
- Define the substance requirements needed to align substance with international tax structures
- Assess the tax risks associated with tax planning structures when they have insufficient substance, including under the proposed OECD Pillar Two rules
- Shee Boon Law, Consultant, International Tax and Transfer Pricing, IBFD
- Francesco de Lillo, Senior Manager European Team, Knowledge Centre, IBFD
This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments:
- Inhouse tax professionals and advisers looking to assess whether and how much substance is needed to satisfy specific tax requirements in their corporate tax structures
- Legal professionals assessing the risk of tax controversy associated with tax structures
- Government officials reviewing and auditing domestic anti-abuse rules, transfer pricing rules and tax incentive regimes
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.
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.
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.
