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DTSTAMP:20260422T015904Z
DTSTART:20221101T151500Z
DTEND:20221101T163000Z
SUMMARY:Lights out for holding companies? The flight from havens and the 
 evolution of source tax – whither withholding tax\, intangibles and roya
 lties?
DESCRIPTION:There is pressure to limit the existence and recognition of h
 olding companies only to the extent that underlying substance and functi
 on is housed within the relevant jurisdiction. International tax law dev
 elopments of the recent past and of the foreseeable future provide broad
  legal rules based on the OECD/G20 and the EU’s efforts to crack down on
  companies with slim infrastructure in low-tax jurisdictions or in count
 ries with tax benefits for pure holding companies (especially IP-holding
  companies). This must be seen together with withholding taxes\, non-ded
 uctibility rules for payments made to companies in low-tax jurisdictions
 \, and the principal purpose test as well as limitation on benefits clau
 ses. This panel will provide an overview of how international groups are
  responding to these developments.
LOCATION:Room 229 A\, Level 2
UID:ceb50182-00ee-4b98-94a7-5af2515323cb
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