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Dear Readers,
2015 really is flying by, and with half the year gone, the nearer we get to those all-important OECD deliverables and further implementation packages in September. The work of the OECD and its BEPS Project has changed the landscape of international business structuring forever, setting the tone for transparency and best practice reforms around the globe. Although we are yet to see how such a large number of tax systems, each with their own set of complications and nuances, are to align, it appears that most are heading in the same direction with their proposed measures.
In addition to the recently released package of measures for the implementation of a new Country-by-Country Reporting plan from the OECD, we have seen proposed changes to the US Model Tax Convention, widely viewed as an acknowledgment of the OECDs BEPS work from the US Treasury (if not fully endorsed by Congress & Senate committees), and the EU Commission move to revive the Common Consolidated Corporate Tax Base (CCCTB). How these initiatives will fit within the OECD framework remains to be seen, but means companies and professional advisers must keep abreast of a broad range of potential changes.
All of the issues around these new regimes will be discussed at our upcoming events across the globe. From our New York meeting in July on the US Model Tax Convention, to our September Paris meeting on Supply Chain Methodology and our Annual Members Conference in London in November. Information on all these events can be found on the IBSA website.
Also, if you missed our recent Workshop on Developing Strategies for International Business, you can read a summary of the presentations and access the relevant slides.
Finally, don’t miss our next London event on 29th September which will be held at Ince & Co on Growth: Funding, M&A and Structuring your Business for Success. Angus Macdonald, the Managing Director of rapidly expanding SME British Renewables will discuss his experience of the growing pains of developing and financing a growing enterprise. Our panellists will provide insight into the ways a company can expand the business through acquisitions, the requirements of financial investors and the potential impediments that could be faced. Issues such as financing the expanded business, developing an acquisition policy, secondary markets (including AIM) and exit strategies will all be discussed.
Best wishes,
The IBSA Team
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With branches across the globe, we are the worldwide community for practitioners dealing with international business structuring and regulatory compliance. Find out more about us, and how you can become a member by downloading our brochure.
Members of the IBSA are drawn from a wide range of practice, providing advice and services to businesses with footprints in multiple jurisdictions. Members have access to a range of events and resources including Conferences, Webinars, the Knowledge Bank and activity programmes led by local Branches in their country.
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IBSA members receive a discount on all paid-for events, and remember that all of our events are eligible for CPD points.
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September: Discussion Groups
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IBSA Members'
Annual Celebration Dinner
18 November, London
IBSA Annual
Members' Conference
19 November, London
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Our knowledge bank is regularly updated with content from our members and partners.
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Articles from our members
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EU LAW - EXIT TAXES: VERDER LABTEC GMBH VS FINANZAMT HILDEN
Dominic Slattery, CTA, OneE Group
Dominic Slattery of OneE Group highlights the recent CJEU case concerning a German tax law which sought to levy an exit charge on a limited partnership when it transferred various intellectual property assets held by its German Permanent Establishment (“PE”) to its Dutch PE.
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US AND BEPS CONFORMITY: (UN) CERTAINTY
Keith Brockman, Mars UK Ltd
The quoted letter herein, from the Congressional tax-writing Committees to US Treasury sets the stage for future US BEPS conformity and policy approach. This letter is especially revealing after the US has declined an invitation to be a member of the ad-hoc group for creating a BEPS Multilateral Instrument, of which over 80 countries have signaled their positive intent.
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FAILURE TO COMPLY WITH EU LAW: COMMISSION V UNITED KINGDOM C-640/13
Simon Blum CTA ACA, OneE Group
With the ever-expanding powers of HMRC’s Accelerated Payment Notices (“APNs”) regularly in the headlines, this decision by the CJEU provides the reader with a chance to reflect on the EU limitations that new legislation introduced by member states must adhere to
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IStructuring Ltd (trading as the IBSA) is a private limited company, registered in England and Wales with registered Company Number 08840738. Business address: 83 Baker Street, London, W1U 6AG, United Kingdom. Registered office: 44 Southampton Buildings, London WC2A 1AP, United Kingdom.
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