We are seeing a significantly increased level of challenge from Tax Authorities globally in the areas of Economic Substance (‘ES’) and Beneficial ownership (‘BO’) in the context of cross-border withholding and non-resident capital gains taxes. This challenge arises from increased international transparency, an increase in joint audits, exchange of information between tax authorities and recent international case law. In addition, Tax Authorities have started applying general anti-abuse concepts and it is likely that challenges around the Principal Purpose Test (‘PPT’) will emerge soon too.
Our webinar series aims to provide a comprehensive overview of the latest developments and challenges in beneficial ownership, economic substance and principal purpose test.
The series will cover the following key areas:
Current Activity and Trends: An exploration of the ongoing activity and the emerging trends we are observing globally with the focus on Private Market Funds and Multinational Enterprises.
Technical guidance: Technical guidance providing the presentation of the current developments in domestic and tax treaty law and jurisprudence.
Territorial Insights: Insightful analysis of specific territories, highlighting how different regions are addressing these challenges and what measures can be taken to manage them effectively.
Date, Schedule & Location
We have planned a series of sessions led by our tax controversy and dispute resolution team with colleagues from across the PwC network to ensure a thorough understanding of the subject matter. The schedule is as follows:
Begga Sigurdardottir
Tax Partner, Tax Controversy & Dispute Resolution Leader, PwC Luxembourg
Tel: +352 62133 31 94
Global Co-Leader Tax Controversy & Dispute Resolution, PwC United Kingdom
Tel: +44 (0)7764 235336