London Congress draws to a close with robust discussion on 'ALP 2.0'

The curtains came down in style at the 73rd IFA Congress at London, with the session on 'Recent Developments in International Taxation', an annual fixture at Congresses, producing some robust discussions on the constitutional validity of the unilateral DSTs as also the controversial US provision - BEAT, the latest case laws from across the globe that have made the headlines and laid down some important precedents, how a re-invented ALP 2.0 may look like, latest trends in transparency including a recent directive by the Dutch Banking Regulator and much more... 
 
Click here to read the highlights from the engaging panel discussion on the final day at the London Congress as also our Knowledge Partner DTS's take on the same. 

London Congress comes alive with digital economy debate; OECD previews approaches, USA draws red line

Day 3 of IFA Congress absolutely lived up to its top billing, as the panel comprising of 3 OECD representatives, including its influential Tax Policy Director Pascal-Saint Amans, US Dy. Assistant Secretary (International Tax) at Treasury Department Chip Harter, global tax director of a Fortune 500 company, renowned tax professionals and tax administrators of developing countries, sized up the digital tax conundrum/tax challenges arising out of digitalisation and the possible solutions to the issue dominating the international tax discourse and engaging the attention of G-20! As OECD representatives outlined some possible approaches as a starting point of discussions, what caught everyone's attention was one approach that was deliberated in some detail by the panel - "Residual Profit Split " method to allocate a portion of the excess profits of the corporate among developing countries/jurisdictions which have the consumers/market. The US Treasury representative Mr. Harter had a sharp, nuanced counter-view to the recent unilateral actions of countries to levy a Digital Sales Tax. He drew a red line on what might be palatable to the biggest economy in the world and had a warning for countries that were targeting the big US tech giants! His words at the end of the 2 hour panel, which surely did not go unnoticed -  "This is a pivotal and perilious moment for international tax..."

Click here to read the minute by minute account of an intense and absorbing panel deliberation on how to meet the tax challenges of digitalisation as also our Knowledge Partner DTS's take on the same. 

IFA Congress mulls over taxation of space & more!

Click here to read the key highlights from this panel discussion including country-wise perspective as also our Knowledge Partner DTS's take on the same.

BEPS Action Plan 4 on 'Limitation on Interest Deductions' in spotlight as technical deliberations kickoff

The technical deliberations at the 73rd IFA Congress kicked off in right earnest with a sumptuous platter on BEPS, a topic that has dominated the tax discourse over the last 5 years.  Among the 15 BEPS Action Plans, some have received more attention than the others and one of the Action Plans that has been a "sleeper", which is now gaining some traction in various discussions, is Action Plan 4 on 'Limitation on Interest Deductions.' And this was the Plenary Topic on Monday at the London Congress! The ensemble panel discussed the key aspects of BEPS Action Plan 4 & EU's Anti-Tax Avoidance Directive (ATAD), including their coverage, the definition of interest, interest cap and thresholds, ATAD meaning of 'EBITDA', the optional safe harbours offered by Action Plan 4 and the exception to the rules. 

Click here to read the key highlights from this incisive panel discussion as also our Knowledge Partner DTS's take on the same.

A special message by Philip Baker, Queen's Counsel, UK

We have a special message for our readers from the wizard of International tax and quintessential Englishman Queen's counsel Philip Baker. Click here to read the London Congress sessions Mr. Baker is looking forward to and you wouldn't want to miss his take on the 'Brexit' session at IFA. Mr. Baker also has some valuable tips for overseas delegates on one place they must not fail to visit while they are in London. 

London Congress kicks-off, OECD Secretary-General talks up BEPS progress, eyes digital tax solution

The 73rd IFA Congress at London got underway with a sizzling opening ceremony, the highlight of which was OECD Secretary-General Jose Angel Gurria’s key-note address, which was a sharp, blunt, straight talk on the global tax landscape, which has witnessed a metamorphosis in the 5 years!

Click here to read our detailed coverage of the Opening Ceremony at the London Congress. 

From the President's Desk

On behalf of the IFA Executive Board, the Executive Committee and the London Congress Organising Committee, and on this beautiful autumn English day, a cordial welcome to our 73rd Congress, IFA London 2019...

Click here to read IFA President Mr. Murray Clayson's special message for Congress delegates and Taxsutra readers. 

IFA Cahiers - The Key Takeaways

The 750+ pages Cahiers contains General Report, EU report and branch reports from 44 countries on the topic of 'Interest deductibility: the implementation of BEPS Action 4'. The General Report authored by James Gadwood (United States) Paul Morton (United Kingdom) finds that BEPS Action 4 aroused great deal of concern among MNEs as it departs from the arm’s length standard and adopts mechanical approaches to limiting interest. The authors analyze branch reports from 44 countries in order to understand how countries have implemented BEPS Action 4 and whether countries are moving towards convergence to the agreed common approach. The 980+ pages Cahiers on second plenary topic 'Investment Funds' contains General Report and Branch Reports from 42 countries. The Report surveys the current state of taxation of investment funds around the world and examines assumptions and challenges associated with prevailing policies and theories that have driven the evolution of the domestic and international taxation of investment funds, their investors and managers.
 
Click here to read the key extracts and takeaways of the reports on 'Interest deductibility: the implementation of BEPS Action 4' and 'Investment Funds'

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