It is with great pleasure for us to welcome you to the 70th Congress of the International Fiscal Association (IFA) in Madrid, Spain! We put together all the latest and greatest scientific topics, as well as a multitude of wonderful and unique cultural activities, to make this 70th Congress the most informative and exciting one ever!
This 70th Congress officially opens on September 25, 2016 and will take place at the state-of-the-art IFEMA Convention and Congress Centre, at Recinto Ferial Juan Carlos I in Madrid, Spain. The final day of the Congress is September 30, 2016 so you have six days of experiencing the magic of Madrid!
The IFA Annual Congress providing each year a forum for representatives from both the private and the public sectors, including international tax practitioners, the Courts, Universities and international governmental and non-governmental organizations to come together, bringing their expertise for the benefit of all. There is no better occasion for the tax world to gain truly meaningful, extremely interesting and substantive knowledge on tax ‘hot’ topics, all the while being in the company of old friends and having the pleasure of making new ones.
The IFA Permanent Scientific Committee (PSC) selected the two subjects below for the IFA 2016 Madrid Congress, as well as the corresponding General Reporters:
Subject 1: Dispute Resolution Procedures in International Tax Matters
Many believe that the OECD’s BEPS project could lead to a rapid increase in tax inspections and controversies, as well as an increase in tax disputes between governments. As tax authorities seek ways to test the limits of and possibly to broaden their corporate tax bases, the possibility of double taxation will put additional strain on the mutual agreement procedures, which may already be struggling even before BEPS to cope with demands associated with the greater internationalization of income earning activities.
This panel will discuss concrete proposals for addressing this global development, focusing on the root causes of increased tax controversy and challenges to typical resolution processes. The work of the FTA’s MAP Forum and proposals for arbitration and other alternative dispute mechanisms will be considered.
General Reporter: Carolina del Campo (Spain)
Chair: Michael Danilack (USA)
Subject 2: The Notion of Tax and the Elimination of International Double Taxation or Double Non-Taxation
The concept of ‘tax’ and ‘tax on income and capital’ is a fundamental pillar of the international tax system (tax treaties and domestic provisions on the elimination of double taxation). However, the contours of the concepts of tax and tax on income or capital are not clear. This situation often causes conflicts since States’ treaty obligations may be dramatically affected if certain taxes or levies are outside the scope of tax treaties or the domestic law foreign tax credit and exemption provisions.
The recent BEPS initiative is also directly linked with the concept of tax on income and capital, since, in the end, whether there is double non-taxation depends on whether income and capital have been subject to tax, or at least made liable to taxation, in, at least, one State and on the relative comparability of the taxes levied in all the States affected.
The problems to be studied are directly connected with real issues that affect taxpayers and States and current controversial cases will be used as a examples in the session : e.g. is the diverted profits tax in the UK covered by tax treaties? are some taxes levied in some States (e.g. to prevent abuse, taxes earmarked for a specific purpose, extraordinary taxes in periods of crisis) covered by tax treaties /domestic provisions to prevent double taxation or double non-taxation even if they do not have the form of typical taxes on income and capital?
General Reporter: Marjaana Helminen (Finland)
Chair: Adolfo Martín Jiménez (Spain)
There are, as usual, subjects of maximum significance and relevance in international taxation.
We would like to give our enthusiastic congratulations to Carolina, member of the Spanish IFA Board, and to Marjaana, member of the PSC, for being designated as General Reporters of the 2016 Madrid IFA Congress
- Corporate tax officers respond to BEPS
- Taxation of activities performed in breach of legal regulations (illegal activities)
- Making intelligent investment decisions (tax incentives in Latin America and their effectiveness)
- Tax judges Seminar: Access to a Tax Court and the rights to property and to equal treatment
- VAT and direct taxation of digital economy
- Recent developments in international taxation
- Taxation of venture capital: funds, managers and investment structure
- Taxation of sportspersons, sport organizations and sport events
Venue: IFEMA Convention and Congress Centre (Congress venue)
Date: Wednesday, 28th September 2016. Room to be confirmed | 15:15 – 16:45
The YIN Seminar will be divided in two segments. In the first segment, the winner of the Mitchell B. Carroll Prize will present his/her winning thesis. Then the winner of the Maurice Lauré Prize will then present his/her winning thesis. Finally the winner of the IFA President YIN Scientífic Award will present his/her article. Each presenter will answer questions from the audience.
The second segment will be a moot court session. The speaker (name to be announced) will preside over a hypothetical tax case to be argued by young tax academics or professionals, with one side representing the tax authorities and the other side representing the taxpayer.
After the arguments have been put forward, the acting tax judge will render his or her verdict on the tax case. The fact pattern for the case, the legal issues involved and the summary of the parties’ arguments will be made available to the delegates before the start of the seminar.