London Annual Tax Seminar

Date & Time

16 May 2018

Location

Baker McKenzie London office
100 New Bridge Street
London EC4V 6JA

2017 was another year of significant change in the international tax environment, with the US finally passing long-anticipated tax reforms. The pace of change looks set to continue in 2018 with the multilateral instrument coming into force and significant proposals at the UK, EU and OECD level. Some of these proposals call for a fundamental shift in the historically accepted balance between residence and source based taxing rights that will have a profound impact on many multinationals. At the same time, the markedly more aggressive approach by tax authorities to auditing multinationals shows no signs of slowing.

Baker McKenzie's Annual Tax Seminar will explore these themes and the steps that can be taken to prepare for and adapt to this changing landscape. The day will be a mix of thought provoking presentations and smaller discussion breakouts to explore key areas of interest in more detail.

Our international team will be joined by two guest speakers: Tim Harford, Economist, writer of the long-running Financial Times column, "The Undercover Economist" and presenter of Radio 4's "More or Less" programme, and Peter Dowd MP, Shadow Chief Secretary to the Treasury. Together they will inform, enlighten, provoke thought and entertain.

During the seminar we will be holding a selection of breakout sessions detailed below, in which you can choose three to attend. If you would like to register for this event, please click the Register button below.


Global Financing: ATAD, Debt Allocation & the Future of Preferential Regimes

Many groups restructured in 2016 in advance of the implementation of the UK anti-hybrid rules. As the implementation of the OECD’s BEPS recommendations continues, US tax reform is implemented and the EU Anti-Tax Avoidance Directive comes on-line, further changes may be required to ensure effectiveness on a global scale. This session will explore the coming changes and the options available to multinational groups as they navigate them.

What’s in store for the Digital Economy?

Having parked the issue at the outset of the BEPS process, the OECD is moving forward with a new report on the Taxation of the Digital Economy. At the same time, the EU is pressing for the “digital PE” concept to be introduced, and for interim measures, including a turnover tax on digital companies. The UK Government has outlined its views, and its own possible unilateral measures, in a recent position paper. All of this points to the potential for fundamental changes to the way digital companies are taxed. This session will discuss the proposals and make some predictions on what the future might have in store.

IP and Intangibles in a changing world

Time may be up for offshore IP ownership. Recent changes in the tax landscape – including anti-diversion rules, the multi-lateral instrument and treaty changes, BEPS transfer pricing changes, withholding taxes – are all factors making low-substance offshore IP ownership less tenable. This is combined with the ever-increasing importance of technology to value creation, becoming core to primary activities in the value chain rather than IT being simply a support activity. So now's the time for a rethink. And "onshoring" IP is an option. But where do you start? This session will provide the answers.

The future of financial services - FinTech

The financial services industry is experiencing a period of rapid change, with new technologies, market entrants and regulation coming together to create increased competition and innovation. Traditional financial services providers must keep pace either through launching competing technology or through acquisition. In this session Sue McLean, a FinTech specialist, will provide an overview of trends in the FinTech space, and our team of tax specialists will evaluate what this means from a UK and international tax perspective.

The Future of Double Tax Treaties

How important and effective will double tax treaties be in providing relief from double taxation and effective dispute resolution mechanisms in the future? The ground-breaking multilateral instrument has resulted in the substantial changes to the global treaty network. Do these changes make treaties fit for purpose, ready to address the challenges of an increasingly complex world? Or do they represent the first stage in a futile effort to maintain relevance in a time of increasing unilateral measures? This session will explore these questions.

Tax Controversy Clinic – What we are seeing and strategies to deploy

This clinic will discuss recent audit experience in the UK in relation to transfer pricing, corporate tax and VAT including how HMRC are changing their behaviour and technical approaches. We will also consider how to resist HMRC's challenges and 'win' the audit. As tax controversies are increasingly international in nature we will also be joined by tax controversy experts from France, Italy, The Netherlands and Germany.

US Policy and Tax Reform

After much uncertainty, in December 2017 the US Congress passed the most significant changes to the US international tax rules in 35 years. In this session we will discuss the Tax Cuts and Jobs Act and its implications for the international tax environment. This session will be run in two parts, one focused on US headquartered groups investing overseas and the other on non-US headquartered groups investing in the US.

For further information please contact Karis Berthier.

Speakers

Guest Speakers

  • Tim Harford
    Senior columnist
      Financial Times
  • Peter Dowd
    Member of Parliament
      Bootle