Newsletter | May 2015

Dear Readers,

  

  

Much has happened since our last newsletter, with the UK electing a majority Conservative government for the first time since the 1990s; the Obama administration facing difficulties in the twilight of its term in office with its attempts to revise the tax code via a change in CFC rules, instead pursuing changes to its MTCs in a major acknowledgement of the impact the OECD's BEPS work; the OECD itself revising various BEPS Action Points in the lead up to its formal recommendations later in the year and the closening of EU ties between Germany and France.  

  

The decision by Amazon to record sales in the UK, Germany, Spain and Italy, with France in the pipeline, also demonstrates the changes in much of the business structuring landscape over the past two years and a recognition that country-by-country reporting will be the new norm.

  

Next week sees the first IBSA Workshop take place in London on Developing Strategies for International Business. The last few places remain so don’t miss Phillip Baker QC’s session on ‘The Post-UK-Election Landscape for SMEs with Global Interests'. There will be interesting sessions from Close Brothers, Squire Patton Boggs, NERA Economic Consulting and IBSA Founder, Roy Saunders. Sessions are tailored around a typical entrepreneurial group structure and ways to develop business growth.

  

July 14th sees the IBSA North American Branch discussing the US Model Tax Convention: A New Worldfocussing on the newly announced Treasury proposals to the US tax treaty which are widely seen as an acknowledgement of the OECD BEPS project, in particular Action 6. The proposals cover changes to permanent establishment rules, denial of treaty benefits, changes to Limitation on Benefits and other proposals designed to limit inversions. The changes are significant and will make for an energetic discussion. This event is kindly hosted by Frank Hirth at their New York offices. Register now to secure your place.

  

Finally, the IBSA annual conference will take place on Thursday, 19th November at the Landmark hotel in London. Please save the date! IBSA Members will be contacted shortly to discuss the conference format and will also receive an invitation to our first Member’s Dinner & AGM to take place on the evening of 18th November.


Best wishes,

The IBSA Team

IBSA Events

IBSA members receive a discount on all paid-for events, and remember that all of our events are eligible for CPD points.

Developing Strategies for International Business 

Workshop

Join us in London for a practical one-day workshop, at which we will discuss and examine a typical entrepreneur's international group structure, addressing areas including Transfer Pricing, Tax Incentives and the OECD BEPS project.


View the full programme


Discounts are still available when you book 2 or more places.

Date & Time:
4 June, 08:30-17:00
Venue:

Pricing*

£199 - IBSA Members

£399 - Non Members

 

*All prices are exclusive of VAT, Terms & Conditions apply. More information »

IBSA Member Benefits

As the worldwide community for practitioners dealing with international business structuring and regulatory compliance, we are pleased to offer our members the following exclusive benefits. If you are not yet a member, please download our new brochure and find out more about what we do, and how we may be of benefit to you.

Exclusive offers for our members

Red Wasp Marketing

Google certified partners, Red Wasp Marketing are specialists in the full build and management of paid search campaigns for the professional services, and have the expertise to continually interpret data so you can you make better decisions and maximise your returns.


Whether you are completely new to paid search, or already have an established account and would simply benefit from a review of your existing arrangements, Red Wasp can help.

Contact:

Comtax Tax Structuring Tool

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Our knowledge bank is regularly updated with content from our members and partners. As well as the member-contributed articles below, we have also added two new reference items from Jordan's Competition Law Journal: The Double Duality of Two-Sided Markets and The Intel Case In A Broader Context : Can We Learn Some Lessons From The Us Perspective?

Articles from our members

SPECIAL TAX REGIME OF SOCIMI (SPANISH REIT’S)

Alix Sáenz de Cenzano Fargues, Jaime Azcona, Azcona & Asociados


The Spanish REIT’s, locally called “SOCIMI” (Sociedades Anónimas Cotizadas de Inversión Inmobiliaria) are enjoying a significant boom in Spain due to important tax benefits and the economic rebound of the Spanish property market.

EUROPEAN COMMISSION: TRANSPARENCY BLUEPRINT

Keith Brockman, Mars LTD

Commissioner Moscovici’s recent speech addressing the future of tax policy aims at developing an ambitious blueprint for taxation in Europe.

CAN FOREIGN COMPANIES BE USED IN INTERNATIONAL BUSINESS STRUCTURING?

Roy Saunders, IFS Consultants

This article considers the use of foreign companies in international business structures, and whether they are still viable following the treaty limitation provision of Action Plan 6 of the BEPS initiative. The review of how a client in Residonia has to work out whether a subsidiary in Forenzia can benefit from its treaty with Bizlandia where business operations are to be carried out makes for sobering reading. If one of the objectives of a double tax treaty is to stimulate international trade and encourage investment, the OECD are certainly shooting everyone in the foot with its current approach.

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.