Cross-border tax disputes and recent cases

The ever-expanding level of globalization has led to an increase, among other things, in cross-border business activities. Cross-border relations between different business entities and their interactions with the tax authorities of the countries involved are regulated largely by domestic tax laws and a wide range of tax treaties. However, a significant number of cross-border tax disputes are emerging in all parts of the world due to various reasons including information asymmetry, disagreement on the facts of a given case or different legal interpretations of the same facts as well as different interpretations of tax treaties.

This webinar discusses cross-border tax disputes and key recent cases from Africa, Asia, Europe, Middle East, North America, and South America in relation to corporate tax structuring. It covers a broader overview of the main causes of cross-border tax disputes and key recent cases on the application of anti-abuse rules, as well as the interpretation and application of tax treaties. Our instructors will share their practical experiences on these aspects and the way forward.

Topics Covered

Block 1: Main cause of cross-border tax disputes in relation to corporate tax structuring 

Block 2: Key recent cases on the application of anti-abuse rules

Block 3: Key recent cases on the interpretation and application of tax treaties

Learning Objectives

After this webinar, the participants will be able to: 

  • Differentiate the causes of cross-border tax disputes in key recent cases
  • Identify the key principles established by these cases in addressing cross-border tax disputes
  • Compare and contrast the positions taken by different parties to the dispute
  • Assess the practical impact of the decisions of key recent cases

Instructors

  • Johanne Hague, Barrister-at-Law, Founder, Prism Chambers, Mauritius
  • Christos A. Theophilou, Partner, International Tax and Transfer Pricing, TAXAND, Cyprus
  • Shee Boon Law, Consultant, International Tax and Transfer Pricing, IBFD, The Netherlands
  • Gabriela Rodríguez Arguijo, Associate Latin America Knowledge Group, IBFD,The Netherlands (facilitator)

Field of study

Taxes
 

Who should participate

This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments:

  • In-house tax professionals and advisers looking to assess main causes, trends and the impact of cross-border tax disputes in different regions and jurisdictions in relation to corporate tax structuring
  • Legal professionals assessing the risk of cross-border tax disputes associated with the interpretation and application of tax treaties and domestic tax law in different jurisdictions 
  • Government officials involved in the interpretation and application of tax treaties and domestic tax laws regarding corporate tax structuring and anti-abuse provisions – particularly those responsible for auditing activities of multinational enterprises 

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and be familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 13 July 2023

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. NASBA CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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