Recent Developments in International Tax Planning considering BEPS and the MLI

25 November 2019, Monday - 27 November 2019, Wednesday

09.00AM - 05.00PM

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Programme Synopsis

This three-day intermediate-level course focuses on international tax planning structures of multinational corporations following recent international developments, such as the Base Erosion and Profit Shifting (BEPS) Project, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and the new OECD Transfer Pricing Guidelines.

The course is designed to provide participants who deal with international tax planning with the latest updates on tax treaty and transfer pricing developments relevant to their day-to-day work. It covers, through a combination of formal presentations and case studies, the practical implications these recent developments may have on existing structures that rely on tax treaties and highlights the risks associated with their use in the post-BEPS world.

Programme Outline

• Setting the scene 
• OECD multilateral instrument 
• The MLI in practice - an example
• Substance considerations in international tax planning
• Substance and permanent establishments 
• Substance in global value chains
• Recent EU anti-tax avoidance developments
• Unilateral BEPS-motivated domestic law measures
• Transfer pricing post-BEPS
• Case studies

About the Presenter(s)/ Trainer(s)

Mr Bart Kosters
Senior Principal Research Associate

Bart Kosters is a Senior Principal Research Associate in IBFD’s Tax Services Department in Amsterdam. He has over 30 years of experience in domestic and international taxation. His areas of expertise are, amongst others, drafting of personal income tax and negotiation and application of double taxation conventions including conducting mutual agreement procedures and litigation.

Prior to joining IBFD in 2001 he worked for the Dutch tax administration and as a senior policymaker in the Ministry of Finance of the Netherlands. Mr Kosters has provided technical assistance as key expert to governments in a large number of African and Asian countries in the areas of tax policy, negotiation and application of tax treaties, drafting tax legislation and the international aspects of domestic taxation. He has also provided training to tax authorities including those of India, the United States, Malaysia, Botswana, Bhutan and Norway, the Big 4 and the European Commission.

Mr Kosters holds a master’s degree in Tax Law from Leiden University, the Netherlands and has lectured International Tax at Radboud University Nijmegen, the Netherlands. Furthermore, he is responsible for IBFD’s Tax Training courses in South East Asia and is a permanent contributor on international tax matters for a leading weekly tax magazine in the Netherlands and is a regular speaker at tax conferences.

Mr Tom Toryanik
Tax Director

Tom Toryanik is Tax Director at Deloitte, based in Singapore. Prior to joining Deloitte, he worked for the Royal Bank of Scotland as Head of Tax for South East Asia and Australia.

He also worked at PricewaterhouseCoopers in Sidney, specializing in taxation of financial services – banking and insurance, and in 2007 spent a year at IBFD as a Senior Research Associate for Australia and New Zealand.

Mr Toryanik holds a master’s degree in International Taxation from the University of Sydney and is a frequent presenter at industry forums.

Mr Hemal Zobalia
Deloitte Haskin & Sells, India

Hemal Zobalia is a Partner with Deloitte Haskin & Sells, India. He has been advising clients on tax and regulatory matters for over 22 years. He is specialized in international tax and has extensive experience in cross-border tax issues. He helps clients in developing appropriate strategies for corporate and international taxation.

Mr Zobalia is a member of the Institute of Chartered Accountants of India. He is a regular speaker at various forums including IBFD Tax Courses and has contributed several articles to respected journals, newspapers, etc. Mr Zobalia is the co-lead author of a book/compendium on tax and regulatory implications of engineering, procurement and construction (EPC) contracts.

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