70th Congress of the International Fiscal Association (IFA) 2016 Madrid

  • Conference Call
  • 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.

    Con­gress Subjects

    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

    Sem­i­nar Programme

    • 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)
    • IFA/​EU
    • IFA/​OECD
    • 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

    YIN Seminar

    Venue: IFEMA Con­ven­tion and Con­gress Cen­tre (Con­gress venue)

    Date: Wednes­day, 28th Sep­tem­ber 2016. Room to be con­firmed | 15:1516:45

    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.

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