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Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, eva.sabaliauskaite@ktu.lt
Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. executive@ktu.lt 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.
Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, eva.sabaliauskaite@ktu.lt
Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. executive@ktu.lt 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.
Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, eva.sabaliauskaite@ktu.lt
Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. executive@ktu.lt www.executive.ktu.edu
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
Practical Workshop & Analysis
14:45 – 15:00 Coffee
15:00 – 16:30 Session 4: Changes in Selected Countries
- EU countries
- Lithuania
- Latvia
Practical Workshop
Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, eva.sabaliauskaite@ktu.lt
Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. executive@ktu.lt www.executive.ktu.edu
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
Practical Workshop & Analysis
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?
Practical Workshop & Analysis
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
Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, eva.sabaliauskaite@ktu.lt
Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. executive@ktu.lt www.executive.ktu.edu
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.
Eva Sabaliauskaitė, Business development and sales director, +370 699 95 779, eva.sabaliauskaite@ktu.lt
Gedimino g. 50-101, LT-44239 Kaunas, Lietuva. executive@ktu.lt www.executive.ktu.edu
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