Annual International Tax Conference
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Taxation of Controlled Foreign Companies
The speakers are:
- Peter Koerver Schmidt, Professor WSR, Copenhagen Business School, Academic Advisor, CORIT Advisory
- David Kleist, Associate Professor, University of Gothenburg
- Juha Lindgren, Professor, University of Vaasa
- Lars Nyhegn-Eriksen, Vice President and Head of Tax, Danfoss
How to sign up:
Please sign up here. At this sign-up page, you can read more about the conference and the speakers
The deadline for signing up is: 6 November 2019.
The participation fee amounts to DKK 500 + VAT (a total of DKK 625).
University researchers and students entitled to SU can participate free of charge.
However, the number of free spaces reserved for university researchers and students is limited.
On request, course diplomas can be issued to the participants.
Please contact Michalla Rosendal by email (seminar.jur@cbs.dk) no later than one week prior to the conference.
Program:
13.00: Welcome
Peter Koerver Schmidt, Professor WSR, Copenhagen Business School, Academic Advisor, CORIT Advisory
13.15: CFC taxation – Background, BEPS and GloBE
Peter Koerver Schmidt, Professor WSR, Copenhagen Business School, Academic Advisor, CORIT Advisory
Peter will start out by briefly discussing the policy rationale behind CFC legislation and the spread of these rules across the world. Subsequently, Peter will present the CFC-related outcome of the BEPS project. Finally, Peter will consider the highly debated global anti-base erosion proposal (GloBE) recently put forward by the OECD and reflect on its consequences for the future of CFC rules.
14.00: Implementation of the ATAD CFC rule across the EU with specific focus on Denmark, Sweden and Finland
David Kleist, Associate Professor, University of Gothenburg
The focus of David's presentation is on the implementation of the ATAD CFC-rules in the EU member states,
and will cover, among other things the following questions:
- What are the issues that have been most debated in the connection with the implementation?
- Does the implementation lead to harmonisation of CFC regimes?
- Which reasons can there be for differences in the implementation?
14.50: Coffee break
15.10: Post-ATAD CFC rules and primary EU law
Juha Lindgreen, Professor, University of Vaasa
Juha concentrates on the questions related to CFC rules that may arise from the perspective of EU Primary Law. Some of these issues were nationally taken into account already before the implementation and thus effected the wording of the Directive. Still after the implementation the interpretation of the national CFC rules need a close look from the same perspective.
16.10: CFC rules – Policy observations and practical challenges
Lars Nyhegn-Eriksen, Vice President and Head of Tax, Danfoss
From the perspective of a Danish multinational manufacturing group with significant focus on R&D and acquisitions globally, Lars will focus on the overall strategic perspective of the new Danish CFC rules in the context of the international development. Furthermore, he will analyze the fact the a lot of the data needed for handling the new CFC rules are not existing – a significant part of the intangibles can only be identified indirectly. Furthermore, Lars will comment on the new rules from a process and a risk management perspective.
17.00: Reception
Date: November 13th, 2019
Venue: Ks43, Kilen, Kilevej 14, 2000 Frederiksberg
Sign up here before 6 November