Taxation of Indirect Asset Transfers

This webinar addresses a specific tax issue associated with the indirect transfer of assets that has been a hot topic for debate between taxpayers and tax authorities. Some taxpayers have been stung with a large and unexpected tax bill as countries seek to exercise their rights to tax indirect asset transfers, while some countries have overextended their taxing jurisdiction when seeking to do so. Our instructors will share their practical experience of dealing with indirect asset transfers and managing the associated tax risk.

Topics Covered


Block 1: Capital gains taxation and common tax planning techniques involving indirect asset transfers

  • Domestic law exemption for capital gains
  • Tax treaty provisions and capital gains
  • Double non-taxation arrangements
  • Application of anti-abuse rules

Block 2: Offshore indirect transfers of assets:

  • What is an offshore indirect transfer of assets?
  • Double non-taxation outcome arising from offshore indirect transfer of assets
  • Approaches used to address the double non-taxation problem and their practical implications

Block 3: Cases and examples:

  • Cases on indirect asset transfers – impact of treaty provisions, potential double non-taxation outcomes and application of anti-abuse rules
  • Examples – what are the impact of different approaches that countries may adopt to tax offshore indirect transfers of assets?

Learning Objectives

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

  • Identify the capital gains tax planning techniques that are commonly seen in practice
  • Distinguish between direct and indirect asset disposals that are within the taxing jurisdiction of the source states and those that are not
  • Compare the impact of different tax treaty provisions on the ability of source states to exercise taxing rights
  • Assess whether the application of anti-abuse concepts is appropriate to tax capital gains on indirect asset transfers


  • Speaker: Mario Petriccionne, International Tax Consultant, UK
  • Speaker: Carlos Gutiérrez Puente, Principal Research Associate
  • IBFD Facilitator: Birhanu Tadese Daba, Senior Associate, IBF

Field of study


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 advisers looking to asses whether and how countries may seek to tax indirect asset transfers in their corporate reorganizations and M&A transactions
  • Legal professionals assessing the risk of tax controversy associated with indirect asset transfers
  • Government officials reviewing and auditing domestic capital gains and exit tax rules, anti-abuse rules and associated tax treaty provisions.

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: 24 Jan 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 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).

Webinar registration details

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