Professor, President of the Federal Supreme Court of Finance, Munich
Professor, Head of the Institute for Austrian and International Tax Law, Vienna University of Economics and Business
Barrister and und Queen's Counsel (QC) Gray's Inn Tax Chambers, London
“Joint Audit” – A successfully tested legal tool in international tax law
Head of International Tax Audit Unit, Bavarian Tax Office, Munich
HR Mag. Roland Macho
Regional Responsible East, Team Leader Large Company Audit, Austrian Ministry of Finance, Vienna
MLC-Coordinator, Swedish Tax Agency, Malmö, Schweden
An insight into the experiences with joint tax audits and the exchange of information according to the EU Council Directive 2011/16/EU from the perspective of the Swedish, Austrian and German tax authorities. Description of the respective legal framework for correcting and amending tax assessments. Presentation of a practical case, which in particular deals with questions relating to the passive and active audit right and the reservation of approval by the taxpayer.
Consultants Peters, Schönberger & Partner, Munich
Practical experiences with the implementation of the Authorized OECD Approach (AOA)
Legal Counsel, Bavarian Tax Office, Munich
Senior Tax Auditor, Tax Office, Munich
Head of Division, International Taxation, German Federal Ministry of Finance, Berlin
Three real cases deriving both from the audit practice and applications for advanced rulings. Illustration of the consequences after the implementation of the AOA. The lecture examines the case of a permanent establishment without an essential people function, the questions of the participation allocation and the calculation of the allocation capital. Finally, the technical implementation of corrections is highlighted.
Munich RE, Munich
Cross-border settlement of services after the entry into force of the DTA China as of 1 January 2017
Head of International Tax Audit Unit, Bavarian Tax Office, Nuremberg
Tax Auditor, Bavarian Tax Office, Nuremberg
Taxation of cost allocation contracts and licences in the relationship between Germany and China. An outlook for the further developments in connection with the BEPS Action Point 10. New possibilities for dispute resolutions, after entry into force of the Double Taxation Treaty with China as of 1 January 2017.
Digital transformation of companies and society is in full swing. Based on a real case, the speakers summarise the tax consequences of a “classical” relocation of functions. They subsequently examine whether the conversion of business models in an increasingly digitalised world also represents a relocation of functions, while also considering the additional possible tax consequences that may ensue by that.
Global Head of Tax, Customs & Export Control, BMW AG, Munich
„Any Rights Left?” The position of taxpayers in the center of international auditors’ interest
Head of International Taxation, Federal Ministry of Finance, Berlin
President of the Conféderation Fiscale Européenne (CFE), Brussels
Director, DG TAXUD, European Commission, Brussels
Chief Justice of the Tax Court of Canada, President International Association of Tax Judges (IATJ), Ottawa
Ambassador, Head of Tax Division, Swiss Federal Department of Finance (FDF), State Secretariat for International Financial Matters, Bern
Bilateral effects of cross-border reorganisation
Head of Tax Audit Division, Tax Office, Munich
Directorate for Tax Assessment, International Relations, Rome
The speakers consider the consequences of the cross-border reorganisation, where a foreign subsidiary is transferred to the permanent establishment of the parent company. They clarify the incongruences of the national legislation and focus on the questions of the allocation of refinancing costs, participations and rights in respect of the international Double Taxation Treaty between Germany and Italy.