Previous agendaWednesday, 6 November 2024

International policy makers and tax authorities come together to brief delegates on the latest tax policy developments driving the global tax transparency agenda and the impact this may have on the tax controversy and dispute resolution landscape. This is a valuable opportunity to learn about the latest OECD and EU measures on improving tax transparency as well as about the latest approaches by tax administrations to the litigation of complex tax disputes following a number of key high profile decisions by the Tax Courts.

The global drive towards tax transparency continues to top the agendas of the OECD, the EU Commission, tax authorities, multinationals, and even institutional investors attuned to ESG requirements. Corporations' cross-border tax arrangements remain therefore under intense scrutiny, and the introduction of mandatory global tax information disclosures will guarantee that the drive for transparency continues to be at the core of a responsible tax function. But with greater transparency comes greater risk. This panel will help identify emerging risks associated with public disclosures, consider adequate strategies to satisfy the information needs of tax authorities, and take a look at the role of data management systems in the operationalisation of key transparency requirements.

This session will bring together sitting and former Tax Judges from across the EU and the UK, to explore how they perceive the current battlefield between Taxpayers and Tax Administrations in relation to different types of cross-border tax disputes, with reference to aspects such as, for instance, procedure, case management, fact finding and evidence, as well as applying black-letter case law to controversies steeped in economic argument such as with transfer pricing controversy. A "must attend" session for in-house professionals and tax practitioners alike.

Transfer pricing disputes continue to be at the forefront of the international tax controversy landscape. This panel, bringing together taxpayers, competent authorities and TP economics experts, will explore the latest thinking on managing transfer pricing controversy risk, including the latest case law and how issues surrounding economic substance continue to underpin key Court decisions. Speakers will also analyse if litigation is ever the answer to a TP dispute.

Tax disputes are often described as arising from a difference of technical opinion between a taxpayer and authority. However, underlying that difference is often a difference between what each side wants. In this session Mark Bevington of ADE Tax shares his experience on how this gap can be bridged in different circumstances.

The tax insurance market has doubled in size over the space of 3 years. Tax risks in more jurisdictions than ever are now insurable (including Middle East, Latin America, South Africa, and APAC). This session will focus on the basics of tax insurance, the ‘art of the possible’, and why tax insurance is here to stay. It will include a 20 min Q&A session where all questions will be fielded by Giles Hambly (Head of Tax Insurance at Gallagher).

The new Labour Government has announced that it is going to crackdown on tax evasion. This session covers HMRC's Fraud Investigation Services' strategy, the offence of 'failing to prevent tax evasion' and the new offence of 'failure to prevent fraud', dawn raids, Code of Practice 9, deferred prosecution agreements, account freezing and forfeiture orders, international co-operation with other tax authorities and the use of AI. In-house professionals as well as practitioners will get practical advice on how businesses and their advisors can avoid HMRC criminal investigations and what do when HMRC come knocking at the door.

Taking place in the Tavistock Room (floor -1)

In an increasingly global world, tax disputes are increasingly multi-jurisdictional in character. In this session, we will look at the situations in which international tax disputes can arise, and some of the unique features – such as widely varying legislative frameworks and the different character of different jurisdictions' tax authorities and their preconceptions – that make resolving them a specialist subject. We will also look at the advantages and disadvantages of the dispute resolution mechanisms set out in double tax treaties ('MAP').

Taking place in the Main Conference Hall