IBFD Academic Tax Conference – Taxing Corporates: 2025 and Beyond
Join us at our IBFD Academic Tax Conference 2025, where we explore some of the main aspects of Taxing Corporates: 2025 and beyond.
The event brings together a diverse group of speakers to share insights into the status and future of corporate taxation and potential areas for reform.
Description
We anticipate that the event will provide excellent networking opportunities with leading experts in the field.
Key topics to be discussed at the conference include:
Revisiting Corporate Residence rules in an International Tax Context
Reassessing Tax Treaty Allocation Rules for Corporate Income Tax
Examining Transfer Pricing Issues in Corporate Taxation
Considering revisions to existing proposals for reform of the corporate income tax framework
Corporate Tax in the EU and the US legal frameworks (how they align and diverge)
Considering the Future of Corporate Tax
On the second day of the conference, the 11th IBFD Frans Vanistendael Award will be conferred to an outstanding scholar who has made a significant published contribution to the field of international tax research in the past calendar year. The day will conclude with a presentation of the Key Findings of the 2024 IBFD Observatory on the Protection of Taxpayers’ Rights, offering insights into the evolving landscape of taxpayer rights protection globally.
Event Programme
08:40 – 09:00 Opening Words
Jan Maarten Slagter (CEO of IBFD)
Pasquale Pistone (Academic Chairman of IBFD)
Craig West and Sergio Messina (editors of the conference proceedings)
Chair of the morning session: Pasquale Pistone (Academic Chairman of IBFD)
09:00 – 10:30 Session 1: Revisiting “Corporate Residence” in an International Tax Context
- Christina Allen (Curtin Law School, Curtin University)
Corporate residence: necessary or outdated in global tax policy? - Nicolas Traut (University of Oxford) and Gustavo Weiss de Resende (Vienna University of Economics and Business)
The Tie-Breaker Mechanism in Article 4(3) of the OECD Model Convention: Recent State Practice at the Crossroads of Procedural Fairness, Ease of Administration and Robustness to Avoidance
10:30 – 10:50 Coffee Break
10:50 – 12:20 Session 2: Reassessing Tax Treaty Allocation Rules for Corporate Income Tax
- Paolo Arginelli (Professor of Tax Law - Università Cattolica del Sacro Cuore) and Stefano Maria Ronco (Researcher in Tax Law - Università degli Studi di Torino)
Are tax treaty rules in need of a thoughtful review? - Madalina Cotrut (Bucharest University of Economic Studies, and West University of Timisoara, Romania)
Is Service PE A Viable Solution for Taxation of Enterprises In Case Of Cross-Border Remote Working Employees?
12:20 – 13:20 Lunch break
Chair of the afternoon session: Stephen E. Shay (11th IBFD Visiting Global Scholar, Paulus Endowment Senior Tax Fellow and Adjunct Professor at Boston College Law School)
13:20 – 14:50 Session 3: Adjusting Current Proposals and Reconsidering Framework Options
- Ekaterina Tibilova
The Beneficial Ownership Of the Amount A Profit As a New Fulcrum In Finding the Political Consensus - Anudeep Turaga (Damodaram Sanjivayya National Law University)
Profit Where It's Due: Taxing the Digital Trail with a Destination-based Approach
14:50 – 15:10 Coffee break
15:10 – 16:40 Session 4: Transfer Pricing Issues for Corporate Taxation
- Paul Alcides Nina Nina (International Taxation Research Group of the Pontifical Catholic University of Peru International Taxation Research Group of the Pontifical Catholic University of Peru)
Revisiting the Transfer Pricing Arm's Length Range from the Perspective of Price Theory and Statistical Analysis - Lucas Araújo Barcellos Pinheiro (University of São Paulo (USP) and the Instituto Brasileiro de Direito Tributário (IBDT))
Can Commercially Rational Behavior and the Options Realistically Available be effectively aligned with the Economic Substance of Intragroup Transactions under Transfer Pricing Rules
16:40 – 17:00 Group and speakers’ pictures
17:00 – 17:15 Library tour
17:00 – 18:15 Drinks and bites
Chair of the morning session: Yariv Brauner (Hugh Culverhouse Eminent Scholar Chair in Taxation, Professor of Law, University of Florida)
09:00 – 10:30 Session 5: EU and US: Divergences and Convergences
- Gianluigi Bizioli (University of Bergamo)
The Rise and Fall of Equality in Corporate Income Taxation: The Case of ‘Windfall Profits’ in the EU and the US - Domenico Imparato (Marie Skłodowska-Curie Postdoctoral Global Fellow at the University of Hamburg, Visiting Scholar at the Max Planck Institute for Tax Law and Public Finance)
The "Hidden Sides" in the Taxation of Dividends and Interest for Corporate Europe versus Corporate America
10:30 – 10:45 Coffee Break
10:45 – 12:15 Session 6: Corporate Tax as a Protection or Hindrance Mechanism for State Interests
- Jeremy Bearer-Friend (George Washington University Law School)
Taxing AI Across Borders: The Benefits of In-Kind Remittance for Cross-Border Taxation - Izadora Paulyne Coutinho Pereira (University of São Paulo (USP) and the Instituto Brasileiro de Direito Tributário (IBDT))
Reconciling Legal Certainty in Bilateral Investment Treaties with GloBE Rules: Resolving Conflicts and Safeguarding Cross-Border Investments
12:15 – 13:00 Lunch break
Chair of the afternoon session: Liselott Kana (Head of Department of International Taxation, Internal Revenue Service, Chile; Co-Chair of the UN Committee of Tax Experts)
13:00 – 14:30 Session 7: Considerations for the Future of Corporate Tax
- Naditsa Nikolovska (Sum Up Ltd, Branch Bulgaria)
Tax It Off: Towards unified taxation of Active and Passive incomes - Yariv Brauner (The University of Florida, Levin College of Law)
Taxing corporations as they are
14:30 – 14:45 Coffee break
14:45 – 14:55 11th IBFD Frans Vanistendael Award
Announcement of the winner
Pasquale Pistone
14:55 – 15:10 Presentation by the winner
15:10 – 15:50 Presentation of the Main Findings of the 2024 Annual Report of the IBFD Observatory for the Protection of Taxpayers’ Rights
- Pasquale Pistone
- Philip Baker, King’s Counsel (United Kingdom)
15:50 – 16:00 Closing remarks
Pasquale Pistone