Milan Conference

Friday, 20 October 2017
Milan Conference
Friday, 20 October 2017 14:00 - 18:00 (GMT)

UniCredit Tower
Room Pizzi Cannella
Tower A 12th Floor, Piazza Gae Aulenti

Registration 13.30 for 1400 Start

First session


The Multilateral Instrument – the interpretation and the provisions on the artificial avoidance of permanent establishment status


The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, signed in Paris on 7 June 2017 by more than 70 countries, will soon transform some of the achievements of the BEPS initiative into applicable (treaty) law. The first session of the conference aims at exploring the interpretative implications of a multilateral convention, as opposed to a bilateral treaty, and the provisions related to the artificial avoidance of permanent establishment status.

14:00 - 14:15 Moderator introduction: Piero Bonarelli, Head of International Tax, Unicredit

14:15 - 14:45 Carlo Garbarino, Professor of Tax Law, Bocconi University Milan

14:45 - 15:15 Barry Larking, Independant Consultant

15:15 - 15:30 Q&A

15:30 - 1600 Coffee break

16:00 - 16:30 Mario Tenore, Senior Associate, Studio Maisto e Associati

 16:30 - 16:45 Q&A 

Second session


The Multilateral Instrument – anti-abuse clauses


The Multilateral convention introduces new rules on the prevention of treaty abuse, including a Limitation on Benefits clause. The session is aimed at comparing the new rules with those in the existing Italian treaties and discussing the interaction with domestic anti-abuse rules.

16:45 - 17:00 Introduction: Giovanni Rolle, Partner, WTS R&A Studio Tributario Associato

17:00 - 17:30  Alessandro Turina, Post-Doctoral Research Fellow (IBFD/University of Lausanne), Adjunct Lecturer (Bocconi University)

 17:30 - 17:45  Q&A

18:00 Drinks