Substance requirements in post-BEPS international tax planning

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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.

Topics Covered

  • Block 1: Different types of substance requirements
  • Block 2: Substance requirements in different types of tax planning structures
  • Block 3: Risks and substance

Learning Objectives

After this webinar, the participants will be able to

  1. Differentiate between different types of substance requirements, including those associated with anti-abuse rules and the arm’s length principle
  2. Identify the substance requirements for different types of cross-border corporate tax planning
  3. Define the substance requirements needed to align substance with international tax structures
  4. 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

Field of study


Who should participate

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

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: 4 October 2022, 15:00 (Amsterdam local time)

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 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: NASBA CPE credit – 1 (only applicable to live webinar).

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