5 – 7 April 2017, Barcelona, Spain
The 17th Annual Tax Planning Strategies Conference – US and Europe focuses on practical planning strategies for multinational corporations and their international advisers. The event also provides insight into how government tax officials may view the international tax landscape in light of important international developments that impact corporate taxpayers.
Panelists will include industry leaders, senior government officials, and leading tax practitioners from the United States and Europe. As in past years, the Conference will be supplemented by half-day Private Wealth Management and Tax Executives Workshops on Wednesday, 5 April.
April 2017, 1400 – 1530: Curbing Treaty Abuse in an Ever Changing World
This session will start with an introduction regarding the “standard” tax treaty anti-avoidance provisions, the Principal Purpose Test and Limitation of Benefits provisions, in the context of BEPS, the Multilateral Instrument, the 2015 U.S. model and the EU Commission Recommendation against treaty abuse. Subsequently, the speakers will discuss the general and specific anti-avoidance measures that are already in force within their respective jurisdiction, as applicable in a tax treaty context, with reference to precedents and case law in each of the jurisdictions, and give their view on how such existing anti-avoidance measures may be replaced by the new PPT / LoBs provisions when possibly be implemented in tax treaties through the Multilateral Instrument. With reference to specific examples, in the last part of the session the panel will focus on the issues that may arise in practice when the “new” anti-avoidance provisions enter into force.
– Guillermo Canalejo, Uría Menéndez, Madrid, Spain
– Danielle Rolfes, Washington, DC, USA
– Kimberly S. Blanchard, Weil, Gotshal & Manges LLP, New York, NY, USA
– Gesina van de Wetering, Van Campen Liem, Amsterdam, the Netherlands
– Alberto Bermejo, Ferrovial, Madrid, Spain
– Jörg W. Lüttge, Flick Gocke Schaumburg, Bonn, Germany
– Riccardo Michelutti, Maisto e Associati, Milan, Italy
– Mark Stapleton, Dechert LLP, London, England