Newsletter | October 2015

Dear Reader,


Welcome to the October IBSA Newsletter.


Many of you will be aware that the OECD made its final announcements on the BEPS Project Deliverables last week and are now in the process of digesting what the final rules mean for you and your clients. It is impressive that the OECD has delivered its recommendations within the original timeframe set out to the G20 in 2013. The impact of the new rules will vary around the globe and prove dependent on the political will of countries adopting legislation into their statue books. Different jurisdictions will interpret the rules in their own way and divergences have already been noted between the United States and European countries' likely implementation of the rules.  


If you missed the live OECD webcast you can find out all the crucial details during our live webinar with Philip Baker QC on 23rd October. Philip will offer his views on the impact of the deliverables, the likely changes to expect and whether countries will be able to introduce the appropriate legislation in line with the objectives of the Project. If you are unable to attend the webinar on the day you can register and watch at your convenience via the on-demand service.


Our busy Autumn schedule continued in September with events in London and Hong Kong. Thanks to our hosts at Ince & Co and KPMG, respectively, for providing excellent insights during the discussions. The London meeting focused on business growth and financing opportunities, whilst the Hong Kong discussion centred on new private equity tax exemption rules. A summary of the London meeting can be found here and an article covering issues raised at the Hong Kong meeting will be available soon.


Don't miss out on the IBSA Annual Conference which takes place on 19 November in London. The conference covers keys areas of international business structuring with speakers from 12 countries across 4 continents. The entrepreneur and founder of King of Shaves, Will King, will provide insight into his experiences of financing a rapidly expanding business and the innovative new ways in which funds can be raised. Issues such as IP, tax, funding, economic factors and of course, reaction to the BEPS initiative all feature on the day.


Finally, look out for our first event in Portugal on Investing in Africa. The discussion will examine investment into Africa, exemplified by trade in Mozambique, and will also explore the current fiscal context and the role of Portugal in supporting SMEs trading within Africa; particularly in the context of Renewable Energy Sector.


Make sure you follow the Twitter feed @TheIBSA to keep up to date with all IBSA events and business structuring news.  


Kind Regards,

The IBSA Team


The IBSA Annual Conference

Join us for our one-day conference at which our expert members will provide a comprehensive view of the current issues that affect the international development of SMEs, and ways to overcome them. Covering financing, tax, economic issues, intellectual property and business strategies, this one day event  is a fantastic opportunity to liaise and learn from practitioners from across the globe. Growing a business across borders is now more complex than ever: we are here to make it easier for both entrepreneurs and advisors.

Pricing: £700 + VAT for non-members, £500 + VAT for members

New York, 27 October

Transfer Pricing: The Post-BEPS Landscape


The IBSA North America Branch will host a discussion group on Transfer Pricing on 27 October in New York. Discussion will include the latest reaction to BEPS Project announcements from the OECD including Action Plan 9 addressing the risk aspects of transfer pricing; Action Plan 8 on intangible assets including royalties and transfers of intangible assets; Action Plan 7 addressing the legal issue of Permanent Establishments; Action Plan 4 addressing the ability of multinationals to take intercompany interest rate.


Paris, 29 October

Business Growth: Making the Most of the BEPS Revisions


Panellists including Patrice Lefèvre-Péaron, Roy Saunders and Frederic Dupont will lead a discussion around the following: The OECD and the final BEPS deliverables: using the new rules to best advantage; The opportunities holding companies offer in places such as Luxembourg, Switzerland and Malta; The impact of treaty access limitation and the beneficial ownership concept; Business growth incentives such as reliefs and credits in key jurisdictions, making the most of EU incentives for entrepreneurs

More Events

Webinar, 23 October

Life After BEPS: The Practical Implications of the BEPS Deliverables


Join us on 23 October 2015, at the revised time of 12:00PM BST when Philip Baker QC and Roy Saunders will review the recently announced BEPS Deliverables, providing insight into the practical implications of the new measures and how international businesses will need to adapt.


Register Now

Lisbon, 5 November

Investing In Africa: The Role of Europe in Business Growth Opportunities


The discussion will examine investment into Africa, exemplified by trade in Mozambique. Panellists will also explore the current fiscal context and the role of Portugal in supporting companies trading within Africa; particularly in the context of the Renewable Energy Sector.


Register Now

Hong Kong, 24 November

Indirect Transfer of Chinese Assets


Our panel of experts will discuss the tax implications and issues around the indirect transfer of Chinese assets, sharing their own practical experiences.


Register Now

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Members are encouraged to submit articles to the knowledge bank by contacting joanna.bott@istructuring.com

A summary of the IBSA discussion group which took place on the evening of Tuesday 29 September on the subject of ‘Growth: Funding, M&A and structuring your business for success’.

This articles provides a summary of the recent ruling of the Court of Justice of the European Union, in relation to the deductibility of VAT for holding (parent) companies.

HMRC has provided a technical consultation and explanatory memorandum for new regulations of the UK’s country-by-country (CbC) reporting. Comments are due by 16 November 2015.

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