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Corporate Taxation, Transfer Pricing and FDI Incentives

two day intensive seminar for zone authorities and operators, IPAs, development boards and investors

   Venue:           Amsterdam, 24 - 25 June 2014

International Bureau for Fiscal Documentation


Rietlandpark 301, 1019 DW Amsterdam, The Netherlands, Tel: +31-20-554 0100




EARLYBIRD REGISTRATION to 15th May 2014



“The increasing mobility of international firms and the gradual elimination of barriers to global capital flows have stimulated competition among governments for foreign direct investment, often through tax incentives.” World Bank Group


Introduction


All those concerned with Economic Development are only too aware of increasing competition and the sophistication of those vying for the attention of international and domestic investors. These factors, coupled with the complexities of international tax and finance, have created a need for a Seminar especially designed to cover these issues.


WFZC are pleased to be able to offer such a programme, with the support of the IBFD, which will be particularly suited to officials from Investment Promotion Agencies, Development Banks, Zones and Industrial Parks as well as site selection professionals. The objective is to facilitate discussions with potential investors which will help create the maximum financial and other benefits for all concerned.


This programme follows on from the highly successful visits to the World Customs Organisation and the World Trade Organisation in 2011 and 2012 and offers a unique opportunity to study cross- border tax efficient mechanisms and their impact on investment policies.


About the IBFD


IBFD is a unique centre of expertise offering high quality information and education on International Tax. IBFD’s powerful research platform allows tax practitioners around the world to access this valuable content, on which they can rely to do their work faster and more effectively.


IBFD is the pre-eminent independent (non profit) foundation with the ultimate goal to promote and disseminate the understanding of cross-border taxation at the highest level.


Who Should Attend?


This seminar is suitable for officials from Zone Authorities and Investment Promotion Agencies, Development Banks, Zone and Industrial Parks operators as well as site selection professionals and corporate executives.


PROGRAMME


DAY ONE Tuesday 24th June 2014 Morning

Introduction: Graham Mather Chairman, World Free Zone Convention and President of the European Policy Forum, London and Brussels


09.00 - 10.30 RECENT DEVELOPMENTS IN CORPORATE INTERNATIONAL TAX STRUCTURING


image Corporate tax structuring

image Some practical examples

image The role of tax treaties

image Importance of transfer pricing rules

image What is acceptable and what is not?

image OECD/G20 work on Base Erosion and Profit Shifting


10.30 - 11.00 Break – Refreshments


11.00 - 12.30 HARMFUL TAX COMPETITION vs ACCEPTABLE TAX INCENTIVES


image Recent developments in the concept of harmful tax practices

image What does it mean for the design of tax incentives

image Access to tax treaties

image Tax incentives for financial services

image Tax incentives for research and development and intangibles

image Action 5 of the OECD/G20 work on BEPS


12.30 - 13.30 Lunch


Afternoon


13.30 - 15.00 TAX INCENTIVES AND FOREIGN DIRECT INVESTMENTS


The location of foreign direct investment (FDI) may be influenced by various incentives offered by governments to attract multinationals. In terms of the types of fiscal incentives granted, there is clearly an increasing trend towards offering full or partial tax holidays or tax rate reductions for specific types of activities.


In addition there has been an increasing prevalence for accelerated allowances, generally for investment in plant, machinery or industrial buildings, or a combination of allowances for investment in training, research and development or similar types of activities.


Regional incentives aimed at assisting the economic development of rural or underdeveloped areas are also important tools.


Factors such as transparency, simplicity, stability and certainty in the application of the tax law and in tax administration are often ranked by investors of equal importance to special tax incentives. Control of government finances is also identified as a key element, which helps provide stability in tax laws and thus greater certainty over tax treatment, as well as greater stability and less risk in the economy overall.


In the case of export incentives these apply to almost all taxes, whereas with other kinds of incentives, the trend is towards a more selective exemption or partial exemption.


15.00 - 15.30 Break – Refreshments


15.30 - 17.00 Tax Incentives and Foreign Direct Investments (continued)


DAY TWO Wednesday 25th June 2014 Morning

09.00 - 10.30 Transfer Pricing Aspects of International Tax Structuring


image The importance of arm’s length principle in tax planning

image Legal framework

image OECD Transfer Pricing Guidelines

image Tax structuring for debt and transfer pricing

image Tax structuring for manufacturing and distribution activities and transfer pricing

image Tax structuring for intangibles and transfer pricing


10.30 - 11.00 Break – Refreshments


11.00 - 12.30 Value Added Tax


image VAT refresher

image VAT valuation rules

  • taxable amount under VAT/GST

  • definition of “open-market value”

  • TP: VAT versus income tax

  • case law

image Interaction between TP adjustments and VAT

image TP adjustments and consequences for VAT purposes

image VAT adjustments and consequences for TP

image Profit allocation vs place of supply

image Timing issues


12.30 - 13.30 Lunch


Afternoon


13.30 - 15.00 Customs Valuation: Principles and Relation to Transfer Pricing


image Basic customs principles

image Introduction to customs valuation

  • background (function/importance)

  • WTO valuation code

  • developments

image Where do the issues coincide?

image Similarities/differences

image Comparing the valuation methods

image Intellectual Property under customs valuation principles


15.00 - 15.45 Visit to IBFD Library – Break – Refreshments


15.45 – 17.00 Roundtable Discussion


PRESENTERS INCLUDE


Shee Boon Law is the Manager of Tailored Tax Courses and Research Services in IBFD. Prior to joining IBFD, he was a tax adviser with the Inland Revenue Department of New Zealand. Mr Law also worked for the OECD and was responsible for many aspects of the OECD’s relationships with non-OECD economies, particularly in developing policy dialogue with non-OECD economies on the taxation of multinationals, financial instruments and financial institutions. He has represented IBFD and the OECD at many international seminars and conferences. Mr Law has a doctorate degree in Accounting.


Ruud Tusveld is partner in charge of the Dutch Customs & International Trade practice of PwC, leader of the PwC EMEA Customs & International Trade group and global coordinator for the Customs network worldwide as a member of the global indirect tax leadership team of PwC. He is involved in customs consultancy of any kind, but specializes in customs regime aspects related to distribution and production of goods (customs warehousing, processing reliefs and centralized solutions), customs valuation (in relation to Transfer Pricing) and excises, in all cases combined with advisory on the related main international VAT aspects.


Furthermore, as a lawyer, Mr Tusveld is in charge of running appeals and court proceedings on customs and international trade issues on behalf of clients. Based on his experience of over 27 years in the field of customs he has gained a broad insight in customs and excise issues on a global basis. As a result, he also assists major companies in setting up and optimizing their customs function and processes. On this subject, he is responsible for a number of these companies as global engagement partner for Customs & International Trade.


As a lecturer, Mr Tusveld is involved in postgraduate customs courses at the Erasmus University in Rotterdam and for the Association of Tax Lawyers in the Netherlands (NOB). He is the author of a book on processing reliefs and co-author of a book on origin compliance.


Boyke Baldewsing is a Principal Research Associate at IBFD. He has extensive experience in the (inter)national tax arena, including in senior in-house tax functions with financial institutions and for some years as a lawyer at the Amsterdam Bar. Mr Baldewsing has also worked as a Dutch and international tax expert for various Big Four and law firms.


His experience covers, inter alia, tax advice, tax opinions, chairing technical meetings, coaching junior tax professionals, managing client portfolios, and advising on and negotiating tax rulings. Mr Baldewsing has been a senior registrar at the Tax Chamber of the Court of Appeal in The Hague for four years, and has also been a co-writer of several tax articles, visiting lecturer at Nyenrode University, and participant of the tax committee of the Dutch Association of Banks. He is currently a member of the Dutch association for tax science and is also involved in a number of community organizations. Mr Baldewsing has a master’s degree in Tax Law from the University of Leiden.


Shima Heydari joined the VAT team at IBFD in July 2012. She is a qualified solicitor of England and Wales, having qualified in tax law in 2004. She specialized in VAT on joining PwC London in 2006 concentrating on advising financial institutions. In 2008, Ms Heydari began working as a Senior Manager at PwC Amsterdam, where she worked on both Dutch and international VAT projects, led VAT seminars and gave tailor-made VAT courses to clients.


Bart Kosters is a Senior Principal Research Associate in IBFD’s Tax Services Department. Until January 2010, he was in charge of the IBFD Topicals Knowledge Group and until August 2005 he was the Head of the IBFD Asia-Pacific Research Team.


After obtaining his master’s degree in Law from the State University of Leiden in 1988, Mr Kosters started working in the Dutch tax administration where he successfully completed the postgraduate programme for tax inspectors. From 1992 to 2001, he was a senior staff member at the Dutch Ministry of Finance where he was responsible for tax treaty negotiations and application as well as for drafting direct tax legislation. From 2006 to 2009, he was the Key Expert Taxation in the European Technical Assistance Programme for Vietnam (ETV2). Furthermore, he is a permanent contributor on international tax matters for a leading weekly tax magazine in the Netherlands and is a regular speaker at tax conferences.


ADMINISTRATIVE DETAILS


Registration To register please complete the form below and send to the fax number indicated or register online or send an email to info@freezones.org


Registration Fees


Two Day Seminar £1,800 which includes the full programme as shown on the brochure. The fee also includes two lunches, all coffee breaks and detailed course documentation prepared by IBFD. All participants will receive a Certificate of Completion.


Earlybird Registration closes on the 15th May, see Discounts below.


Special hotel rates have been negotiated at a range of nearby hotels at rates between €120 excluding breakfast and €145 inclusive of breakfast and local taxes per night.


With their acknowledgement of registration participants will be sent a list with links to make their booking direct with the hotel.


Visa Support


Delegates who need visa support letters should register AS EARLY AS POSSIBLE to the WFZC Secretariat being sure to give their passport information on the application form as requested. Full information is available on the following website: http://www.government.nl/issues/visa-for-the-netherlands-and-the-caribbean-parts-of-the-kingdom/short-stay-visas-for-the-netherlands


Discounts including EARLYBIRD REGISTRATION


A 15% discount for each second and subsequent delegate from the same organisation is available, or a 15% discount for each delegate from LDC status countries. An Earlybird discount of 20% (not cumulative) will be offered for all participants who register and pay for their fees by the 15th May.


ON RECEIPT OF YOUR REGISTRATION WE WILL FORWARD OUR INVOICE FOR PAYMENT BY BANK TRANSFER OR CHEQUE. FEES ARE PAYABLE IN ADVANCE – THE ORGANISERS RESERVE THE RIGHT TO REFUSE ADMISSION IF PAYMENT HAS NOT BEEN RECEIVED.


Please contact us before the event if for any reason you have not received written acknowledgement of your registration.


Terms and Conditions Our full terms and conditions including Cancellation Policy are found on www.freezones.org


EARLYBIRD REGISTRATION FORM


To WORLD FREE ZONE CONVENTION 35 Spring Gardens, London SW1A2BA Date …..................................................

Please register the following participants at the Earlybird Registration Fees. We understand that fees must be received by the 15th May to benefit from these reductions.


Send by Fax to +44 870 131 9578 (Please photocopy this form for each delegate) or email to

info@freezones.org


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WFZC The authoritative meeting place for the world’s free and special economic zones


35 Spring Gardens, London SW1A 2BA, UK Tel. +44 207 839 1334 Fax. +44 870 131 9578


General Administration         Email: info@freezones.org