Substance after BEPS: more emphasis on actual conduct, control over risks and the financial capacity of related parties.
Several BEPS action points and deliverables directly touch on the question of substance/people/functions. Action 1 on the Digital Economy and how it operates, Action 5 Harmful tax practices and nexus approach, Action 6 on Treaty Abuse, Action 7 on the Definition of permanent establishment and Actions 8 to 10 on Transfer Pricing and Value Creation. There are also ongoing discussions on the substance requirements for intermediate finance companies and holding companies. With the OECD, the European Commission and local tax authorities on the watch for tax planning, a lack of substance is an easy target. Our training course will examine this new guidance from an OECD, EU and Dutch Transfer Pricing perspective and what this means in practice.
12:30 p.m. Welcome and lunch
1:00 p.m. Course commences
3:00 p.m. Tea/coffee break
3:15 p.m. Course resumes
5:15 p.m. Drinks
6:00 p.m. End
Agata Uceda, Jeroen Kuppens, Mark Bonekamp, Fred van Horzen, Peter Karman and Tjeerd Klik.
NOB PE points/hours
We believe that this training course complies with the course requirements stipulated in the PE Regulations of the Dutch Association of Tax Advisors (Nederlandse Orde van Belastingadviseurs; NOB). You can earn 4 PE hours by attending the course. Participants will receive a certificate of attendance.
For registration information please contact Chantal Helmstrijd at T +31 (0)88 909 1075 or by E-mail. For information about the content of the training course please contact one of the trainers.
€ 375,- exclusive of VAT.
Datum: 28 May 2018
Time: 12:30 t/m 18:00