Impact of OECD and EU BEPS on the tax planning

Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, [email protected]

Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. [email protected] www.executive.ktu.edu

IMPACT OF OECD AND EU BEPS ON THE TAX PLANNING

CONTENT OVERVIEW

During the months of October and November 2015, the OECD and G 20 followed by EU in

December 2015 - all have endorsed the BEPS recommendations and committed to their

implementation. These recommendations on how to reduce the Tax Base Erosion and Profit

Shi-ing as well as related Harmful tax competition and Aggressive Tax Planning are now

being transformed into legislative measures adopted in domestic law.

These changes include new domestic anti-avoidance rules as well as changed approaches

to Transfer Pricing and also measures aimed at reduction of abuse of tax treaties. In the

near future we may see number of tax treaties renegotiated either as a consequence of

multilateral or bilateral action or we can see them simply terminated.

These resent changes was a true earthquake for International Tax Planning and while the

world, as we know it, still stands - it has been significantly changed and further changes are

in process.

Tax Planning will never be the same and you may want to make sure that your advice to

your client is still correct or that the advice you received from your tax adviser or lawyer

years ago is still keeping you on the save side.

Participants will learn to identify what are the challenges of the recent developments to the

tax planning opportunities they have been exploiting, what are the new limits to designing a

new tax planning structure and also what steps they may have to take to improve their tax

planning structures in order to use them in sustainable way for company’s value creation.

Taken the important developments in this area in the EU and OECD, the participants will

also obtain detailed explanations, challenges and opportunities of the latest developments in

this area.

www.executive.ktu.edu



WHO SHOULD ATTEND

CFO‘s Tax managers

Tax Lawyers and Consultants Finance and Accounting specialists doing business cross-border

KEY TAKEAWAYS

Introduction and explanation of 15 OECD BEPS action plans as well as EU BEPS

recommendations, changes and impact on domestic law, Transfer Pricing, Tax

Treaties and International Tax Planning.

Understanding the strategic implications of the current changes for your business

internationally, regionally as well as globally.

Advices for preparing, improving and designing tax planning structure ready for

future in order to use them for company’s value creation.

CORE BENEFITS

Analysis and advises about tax structure to be ready to take the BEPS heat.

Special attention will be dedicated to EU Tax Policy in coming period 2016-2020,

Action Plan of EU Commission and current EU Legislation initiatives and their impact

on tax planning structures in the coming future.

The main issues of tax planning that can be improved before it is too late. This

course will introduce the participants to the OECD and also United Nations initiatives

and challenges for Baltic companies doing business with countries outside EU

including CIS, Central Asia and other Developing countries.

Advises for building and designing tax planning structure ready for future.

Participants will obtain insights and advises on what are the likely implications of

OECD BEPS project for business and tax planning.




PROGRAM

Day one

8:45 – 9:00 Registration. Coffee

9:00 – 10:30 Session 1: BEPS project Explained

- Reasons

- Background

- Outcomes

Practical Workshop

10:30 – 10:45 Coffee

10:45 – 12:15 Session 2: Impact of BEPS

- BEPS roadmap

- Treatment of business depending on size, structure and locations

- Implications of the fast implementation

- What if not BEPS / Saïd Business School vs OECD

Practical Workshop & Analysis

12:15 – 13:15 Lunch

13:15 – 14:45 Session 3: EU Anti-Tax Planning Package

- Anti-BEPS Directive explained

- EU Black-list

- Commission Communication


14:45 – 15:00 Coffee

15:00 – 16:30 Session 4: Changes in Selected Countries

- EU countries

- Lithuania

- Latvia

Practical Workshop




Day two

8:45 – 9:00 Registration. Coffee

9:00 – 10:30 Session 5: Implications for Holding Companies

- Denied or limited access to tax treaty benefits

- Taxation of profits of Foreign Holding Company in home - CFC Rules

- Defenses in domestic law of selected countries


10:30 – 10:45 Coffee

10:45 – 12:15 Session 6: Implications for Intangibles and Patent Boxes

- Changes of Patent Box regimes in Selected jurisdictions

- Transfer Pricing Changes

- Royalty payment non-deductible - why?


12:15 – 13:15 Lunch

13:15 – 14:45 Session 7: Implications for Transfer Pricing

- New transfer pricing approach - why rewriting a contract?

- Intra-group Services

- Country by Country Report preparation

Practical Workshop

14:45 – 15:00 Coffee

15:00 – 16:30 Session 8: Financing Considerations

- End of Hybrid Instruments?

- Interest non-deductible even if paid to a bank?

- What is and is not interest?

Practical Workshop

Resume of the Seminar

- Open questions and discussion




PROGRAM EXPERTS

Tomas Balco, JUDr., FCCA. LL.M,

General State Counselor, Ministry of Finance of the Slovak Republic

Tomas is a tax professional with over 15 years of combined practical experience in private (Big 4: Deloitte & Touche, PricewaterhouseCoopers) and public sectors (Ministries of Finance of Chile, Czech Republic, Kazakhstan, Slovakia, European Commission) as well as research and academia in 4 continents (Latin America, Europe, Africa and Asia) and 9 countries (Czech Republic, Slovakia, Austria, Mongolia, Chile, Belgium, Netherlands, Tajikistan and Kazakhstan).

Modestas Kaseliauskas

JSC „TaxLink Baltic“ partner

KTU School of economics and business, lecturer

COMPETENCES: General Director of the Lithuanian tax administration (2005-2014), head of Šiauliai Country State Tax Inspector, head deputy for taxpayers’ services, head of Tax Law Department (1997-2005)

IMPACT: tax law and planning; tax disputes and negotiations; compliance and tax transparency strategy; tax risks assessment; public sector management.




Jūratė Zarankienė

JSC „TaxLink Baltic“ partner, tax expert

COMPETENCES: over 15 years of experience in finance, with specialization in tax and audit, consulting in local corporate taxation (tax reviews, tax diagnostics, on-going consulting etc.), international taxation (international structuring, transfer pricing, double taxation issues, etc.) and transaction tax (due diligences, acquisition structuring, sales purchase agreements, etc.); tax advisor experience in Ernst&Young Baltics over 7 years.

CLIENTS: EfTEN Capital, BaltCap, Capital Mill, AB Pieno Žvaigždės, Orion Securities, If P&C Insurance AS and etc.

Seminar date

2016 May 9-10

Place

Vilnius

Additional value

16 ACCA CPD credits

Price

999 EUR

* 10% discount for „early bird“ registration until 2016 April 9

** limited number of participants

Language

Programme delivery language – English

Program material language – English / Lithuanian

Follow up programs:

2nd Programme – International Tax Planning- Risks & Opportunities

The focus will be on tax planning top practical issues today in the EU and Globally, its analysis and practical solutions for individual businesses. The programme will include interactive sessions with roundtables.

3rd Programme – Tailored solutions for organisations in Tax Planning

The focus is on the case and analyses of tax planning in an individual organization with purpose to prepare tailored solutions for tax planning and assistance in the implementation process in the organization.

Daugiau informacijos rasite ir registruotis galite čia: executive.ktu.edu/beps


http://executive.ktu.edu/beps

Education

Impact of OECD and EU BEPS on the tax planning