Webinar by Taxand
Date: 26 May 2020
Time: 15:00 – 15:55 UTC
Duration: 55 min
The existing international tax rules may no longer capture where value is created, and many countries are implementing a unilateral digital services tax rather than waiting for international consensus. The Unified Approach on Pillar One is currently the international solution at the table. However, further development is needed and the OECD is ambitiously aiming for the end of 2020. The current COVID-19 situation encourages people to be online more, which further increases the importance of Pillar One.
In 2015 BEPS Action 1 identified that it is difficult to ringfence the digital economy. In 2017 the Inclusive Framework, mandated by the G20 finance ministers, delivered an interim report on the tax challenges arising from digitalisation. This report shows new business models such as the value network (Facebook) and the value shop (Intel) which have a strong reliance on intangible assets, scale without mass and data and user participation. Through several OECD public consultation documents, the Pillar One proposal is now being further developed. This proposal includes both the arm’s length principle and formulary approaches, and increases taxation in market jurisdictions.
In our webinar we will get you up to speed on the issues that need to be resolved. The following topics will be covered:
- Brief overview of the unilateral digital service taxes
- Scope of Pillar One
- New nexus in the user/market jurisdiction
- New profit allocation rule and the interaction with the arm’s length principle
- Dispute resolution mechanisms
Partner, LED Taxand Italy
Paolo is a partner at LED Taxand which is part of Taxand Italy. He has a degree in economics (Università Commerciale Luigi Bocconi Milano) and an advanced LLM in international taxation from the Leiden University (NL). He began his career in 2000 in a Milan boutique tax firm (Studio Mayr); he moved to Italian tax firm Di Tanno e Associati in 2008 and to Fantozzi & Associati in 2013, where he became a junior partner. Paolo joined LED Taxand in January 2018
Paolo has more than 15 years of experience, particularly in international taxation. He mainly focuses on private equity and real estate transactions, as well as international tax planning merger and acquisitions. He is also the author of several publications on international tax matters.
Jimmie van der Zwaan
Partner, Taxand Netherlands
Jimmie is a partner with Taxand Netherlands and a core member of the global Taxand energy service line and transfer pricing service line. Jimmie specialises in the energy sector, covering aspects relating to oil and gas, suppliers and contractors, electricity, alternative resources and renewables. He advises on corporate tax issues and heads the Dutch transfer pricing practice, providing functional and economic analysis, profit allocation and advance pricing arrangements with the tax authorities. He also assists with domestic and international matters such as tax control frameworks, setting up and analysing new businesses and joint ventures, and optimising existing business structures.
Jimmie is a member of the Dutch Bar, the Dutch Associations of Tax Advisors and the International Fiscal Association. He is also a representative for the Dutch Association of Suppliers in the Oil and Gas Industry, and a member of the Dutch Association of Energy Law and Society of Petroleum Engineers.
Jimmie Van Der Zwaan & Paolo Ruggiero