Conference programme

This panel dives into recent court decisions and evolving practices in key jurisdictions. We'll explore how these developments impact how countries assess treaty eligibility and the concept of beneficial ownership in relation to tax treaties and EU directives. Additionally, the panel will examine how these issues interact with broader anti-treaty shopping initiatives and general anti-avoidance rules (GAAR) in these jurisdictions.

This panel delves into the complexities arising from the interplay between the Organisation for Economic Co-operation and Development’s (OECD) global minimum tax initiative (Pillar 2) and cross-border mergers and acquisitions (M&A) activity. Experts will dissect how Pillar 2's rules, including the income inclusion rule (IIR) and undertaxed payments rule (UTPR), impact deal structuring, tax liabilities and the potential for future tax disputes. The discussion will also explore how various dispute prevention and dispute resolution mechanisms may be used to achieve tax certainty under the Global Anti-Base Erosion Rules (GloBE Rules).

Keynote address – update on Portuguese tax environment

This panel dives into the strategic planning of equity and long-term incentive plans for startups with international teams. Experts will navigate the complexities of structuring these plans across borders exploring startup-friendly tax regimes. The panel will address various plan options such as stock options, phantom equity and performance shares, focusing on issues from different qualifications of income , availability of special regimes, moment when income is taxed and existence of exit taxation.

This panel addresses intricate practical tax considerations involved when a company relocates to another country (redomiciliation). The discussion will also delve into current strategies associated with redomiciliation within the context of group restructurings and exploring reliefs that might be available.

This panel explores emerging tax challenges associated with tokenising real-world assets like real estate or shares. Experts will dissect a case study to determine how potential tax triggers at different stages of the tokenisation process (eg, issuance, trading, secondary sales), and navigate the uncertainties surrounding how tax authorities may classify those tokenised assets.

This panel tackles the evolving landscape of international tax disputes. Experts will explore the impact of recent developments like the Mutual Agreement Procedure under the Organisation for Economic Co-operation and Development (OECD) Model, arbitration under the Multilateral Instrument (MLI) and implementation of EU Directive 2017/1852 on tax dispute resolution mechanisms. The session will delve into strategies for managing tax risks, fostering proactive communication with tax authorities and navigating potential disputes in this new era, including interaction with bilateral investment treaties.

This session explores the challenges of attributing profits (source taxation) to specific jurisdictions in today's digital economy. Experts will examine cases how the borderless digital assets complicate the traditional tax frameworks designed for physical goods and local presence. The discussion will delve into potential solutions, including recent Organisation for Economic Co-operation and Development (OECD) initiatives and digital tax proposals.

This session dives into the practical VAT considerations arising during mergers and acquisitions (M&A) involving real estate assets. Experts will dissect the application of VAT to asset purchases versus share acquisitions. The discussion will explore how VAT treatment impacts deal pricing, potential VAT reliefs and the management of VAT liabilities throughout the transaction process focusing on optimal deal structuring.

This panel discusses the ongoing transformation of global tax systems, examining how these changes are impacting different regions and its recent polarisation from UN. Experts will analyse the regional perspectives on Pillar One taxing rights in the digital economy and explore how jurisdictions will respond to these recent developments. Taking a regional perspecive, the panel will analyse the winds of change and their impact on global business strategies.

A series of roundtable discussions will look at recent developments in the following areas:

Topic one: Permanent establishment in digital economy

Topic two: Experiences from MLI implementation in tax treaties

Topic three: Tax issues from blacklisting jurisdictions

Topic four: Special expatriate regimes under pressure