8th Young International Corporate Tax Practitioners' Conference

London
Friday, 18 September 2015
 
8th Young International Corporate Tax Practitioners' Conference
Friday, 18 September 2015 10:45 - 17:00 (GMT)

Deloitte LLP
Auditorium
2 New Street Square
London
EC4A 3BZ
United Kingdom

Map and Directions

The CIOT/ATT European Branch in Association with the Young IFA Network will host its annual conference on current hot international tax topics.

Highlights of this year’s Conference will include:

  • How is BEPS changing the international tax landscape for multinational companies? This will include the impact of new transfer pricing provisions for intangibles and other key items, measures seeking to prevent the artificial avoidance of permanent establishment status and countries pre-empting the BEPS process by introducing new laws, such as the UK’s diverted profits tax.
  • Will double tax treaties continue to be an effective aid to international trade and investment? Areas covered will include the impact of the extension of limitation of benefits clauses and principal purpose tests, the effect of measures restricting relief from withholding taxes on interest and royalties and the approach that will be adopted by HMRC and other tax authorities to claims for treaty relief.
  • A high level panel discussion on the current impact of anti-avoidance provisions on international operations, which will cover recent trends in the application of anti-avoidance measures, including case law decisions, the effect of state aid provisions on beneficial regimes, whether the GAAR has made any difference and the use of clearance procedures, dispute resolution and internal review.

Speakers

Adam Blakemore

Adam Blakemore is a Partner in the Tax department at Cadwalader, Wickersham and Taft LLP’s London practice. Adam advises on the taxation aspects of structuring domestic and cross-border corporate and financing transactions. He has advised on a wide range of financing transactions including securitisations, repackaging’s, credit linked instruments, stock lending arrangements and a variety of financial products. Adam also has experience of advising clients regarding hybrid capital issuances and the taxation of derivative investments. Adam’s practice includes acting on restructurings in solvent and distressed debt situations, corporate reorganisations and reconstructions. He has a particular interest in the structuring and restructuring of regulated and unregulated investment funds and private equity financings and investments. He has also provided advice on corporate acquisitions, demergers and joint ventures, both within the UK and internationally. Adam has also provided counsel on disputes with revenue authorities and has acted in domestic tax litigation, representing clients before the Appeal Courts.

Andrew Dawson

Andrew has spent most of his career in tax.  An economist by background, he is the Head of the Tax Treaty Team in the UK’s Revenue & Customs Department, responsible for the negotiation of the UK’s double taxation treaties.  Before that he worked at the British Embassy in Washington DC.  Andrew has held several tax policy jobs in the Inland Revenue and HM Treasury.  Before joining the civil service, he taught economics, and worked for the Confederation of British Industry. Andrew is currently the Chairman of the OECD Committee on Fiscal Affairs’ Working Party 1 on Tax Treaties, and is a member of the UN’s Committee of Experts on International Cooperation in Tax Matters.

Bill Dodwell

Bill Dodwell leads Deloitte UK’s Tax Policy Group, which manages tax knowledge, training, consultations with the OECD, HM Treasury and HM Revenue & Customs  and Deloitte’s compliance with the UK’s tax disclosure rules.   Bill is Deputy President of the Chartered Institute of Taxation and chairs the CIOT’s Technical Committee.   He specialises in international corporate taxation.

He was a member of the interim Advisory Panel on the General Anti-Abuse Rule.  Bill has represented Deloitte and the CIOT before the UK Parliament, including the Public Accounts Committee and the House of Lords’ Economic Affairs Committee.  He has also represented Deloitte at the European Parliament’s TAXE committee. Bill regularly speaks to the media on taxation and tweets as @ukbudget.

Diane Hay

Diane Hay, Special Advisor, International Tax, PwC LLP. Diane was the Deputy Director at HM Revenue & Customs (2004 to 2008) with responsibility for a wide range of international corporate tax issues, including transfer pricing, Controlled Foreign Companies, company residence and double tax relief. She led the reorganisation of transfer pricing administration in the UK and was the first Chair of HMRC's Transfer Pricing Board. Diane led the team that litigated the UK’s only substantive transfer pricing case, DSG Retail Ltd and others v HMRC (2009), as well as preparing three other major cases for potential litigation. As the UK’s Competent Authority, she had responsibility for the Mutual Agreement and the Advance Pricing Agreement programmes. She also served on OECD’s Working Party 6 Bureau on Multinational Enterprises and was the HMRC representative on the OECD Committee on Fiscal Affairs. Diane joined PwC in London as a Special Advisor on international corporate tax and became one of the first members of PwC’s Global Tax Controversy and Dispute Resolution Network. Her areas of expertise are APAs, dispute resolution and helping clients engage successfully with HMRC.  Diane is currently advising on several APAs with some of the world’s largest and well known businesses across all sectors. In the areas of dispute resolution, Diane advises on both domestic and international cases where she can leverage her excellent relationships with HMRC and other tax authorities. More recently, she has been working with an increasing number of clients who are looking to move their headquarters or centralise their businesses or move assets or people to the UK by helping them to obtain certainty on their future tax treatment across a wide range of issues. Diane has maintained her many relationships at senior levels in both HMRC and HM Treasury which give her a special insight into working with tax officials and excellent access to them.

Ed Wright

Ed Wright is a Director in Deloitte's International Tax practice in London. He advises multinational corporations on UK and cross-border corporate tax issues. His particular focus is on UK parented groups operating overseas and he advises on funding, profit repatriation and the application of the UK's CFC rules. Ed is a Chartered Accountant and a member of the Chartered Institute of Taxation.

Ellis Lambert

Ellis is a Partner in EY’s London Transfer Pricing & Operating Model Effectiveness team.  He has specialised in transfer pricing with EY for 16 years, two of which were spent in the firm’s New York practice. He has experience across a broad range of industry sectors leading transfer pricing design projects and managing APA negotiations and resolving transfer pricing related controversy.  Prior to joining EY, Ellis worked in industry and corporate analysis and has eight years’ experience in strategic and tactical market and industry research covering the telecommunications, information technology and automotive sectors in Europe and Asia. He is a graduate of the University of Warwick where he studied Industrial Economics with a postgraduate diploma in Japanese language

Janine Juggins

Janine graduated in French with German from Manchester University and subsequently trained as a Chartered Accountant with KPMG in London. She is also a Chartered Tax Advisor and Associate Corporate Treasurer. Janine has over 25 years international corporate tax experience gained with companies in the engineering, energy, mining and consumer goods sectors working in both the US and the UK. In 2013 Janine became SVP Global Tax at Unilever, joining from Rio Tinto where she was Global head of Tax. Janine has presented at numerous conferences to share the practical perspectives of a multinational company in the areas of tax and development, the tax policy and design considerations of natural resources taxation regimes, and on the subject of tax transparency.

Jonathan Schwarz

Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is the author of Schwarz on Tax Treaties 3rd Ed and Booth and Schwarz: Residence, Domicile and UK Taxation 18th Ed among other publications and a contributor to Transfer Pricing and Business Restructurings: Streamlining all the way. He is a visiting Professor at the Dickson Poon School of Law, King’s College London. He is a former First Vice President of the International Fiscal Association,  former Vice-Chairman: Committee (N) Taxes, International Bar Association and has been listed as a leading tax Barrister in both the Legal 500 by reference to recommendation for international corporate tax, and Chambers' Guide to the Legal Profession by reference to international transactions and particular expertise in transfer pricing. The Legal 500 has commented that ‘Jonathan Schwarz is a client favourite, particularly for international transactions.’ In the Chambers Guide he is commended for his ‘encyclopaedic knowledge of double tax treaties’

He was appointed to the EU Commission Group of experts on removing tax problems facing individuals who are active across borders within the EU in June 2014.

Penny Hamilton

Penny Hamilton specialises in advice and litigation (including judicial review and references to the European Court of Justice) in VAT, landfill tax, aggregates levy, climate change levy, insurance premium tax, excise and customs duties and European law; advises commercial, financial, education and charitable property, housing and local government clients on a wide range of issues; experience in advising and litigating on behalf of traders affected by MTIC fraud. She served on the Consultative Committee of the Review of HMRC’s Powers, Deterrents and Safeguards and the Tax Appeals Stakeholders Group. Penny is qualified to accept Public Access instructions and she is a CEDR Panel Mediator

Peter Adriaansen

Peter Adriaansen tax adviser, is a member of the Tax practice group in Loyens & Loeff. He divides his time between London and Luxembourg. Peter specialises in Luxembourg and Dutch international tax consultancy relating to private equity, investment funds, holding and financing activities, joint ventures, mergers and acquisitions. He regularly advises Luxembourg listed entities, family offices and international private clients on cross-border structuring. Peter is a member of the Dutch Association of Tax Advisers, and of the International Fiscal Association (IFA) and the Inter-Pacific Bar Association.

Simon Tout

Simon Tout trained with Grant Thornton and KPMG throughout 1996 – 2000 working mostly on corporate tax compliance for owner managed business. He joined Shell in 2000 as the UK Service Company Tax Adviser and after two years took a role of UK Group Tax Planner.  Simon has worked for two years in internal audit based in Nigeria (sub-Saharan) Africa, and Gabon on a rig site set in the middle of the jungle, checking oil tanks for fuel bunkering.  He became the Business Tax Adviser for Shell’s UK Crude & Products Trading business in 2005 and held this role for four years before moving to become Business Tax Adviser for European Gas & Power Trading. Simon current role is UK Senior Corporate Tax Adviser at Shell.

Javier Gonzalez

Javier is based in London and is the Regional Tax Director at Citigroup responsible for Europe, the Middle East and Africa. His prior roles within the Citi Tax Department included International Planning, Mergers & Acquisitions, and country and front office tax support. Prior to joining Citi, he was a Tax Associate at Dewey Ballantine LLP in New York and London.